At the beginning of last year (2025), a new EU legal framework for packaging was adopted: Regulation (EU) 2025/40 on packaging and packaging waste, repealing the previous Packaging Directive 94/62/EC. A key difference from the directive it replaces is that the new regulation is directly applicable, meaning requirements will become considerably more uniform for businesses across the single market. It is therefore not prudent to wait for national transposition. The aim of this article is to provide a concise, substantive overview of the changes, to present the timeline, and to offer sector-wide and sector-specific ideas for getting started now — in a way that minimises costs and ensures that transition period deadlines (2026–2030) do not catch businesses off guard.

Timeline: what happens when?

The regulation has already been published in the Official Journal of the European Union and has entered into force. It applies from 12 August 2026, on which date Directive 94/62/EC also ceases to apply. Certain provisions, depending on the subject matter, have been granted transition periods until 31 December 2028 and 31 December 2029. For the most part, however, 2026 is the optimal time for low-cost preparatory actions — such as data organisation, packaging portfolio mapping, and requesting documentation from suppliers. Taking these steps now makes it possible to avoid significant costs later, when time for design changes will be limited.

From 12 August 2026, a PFAS restriction applies to food-contact packaging, and the new waste container labelling requirements are defined:

  • PFAS substances may not be used in food-contact packaging above the concentration limits set out in the regulation;
  • the European Commission has adopted implementing acts on harmonised labelling for waste containers.

By 12 August 2028 at the latest, member states must have ensured harmonised labelling on packaging waste collection containers.

Refilling and reuse will become measurable:

  • from 12 February 2027, HORECA end-distributors must have established a system enabling consumers to use their own containers for filling beverages and prepared foods;
  • from 1 January 2030, end-distributors with a sales floor area exceeding 400 m² must allocate 10% of their sales floor area to refill stations;
  • from 1 January 2030, at least 40% of transport packaging (e.g. pallets, crates, drums/canisters, wrapping/strapping) must consist of reusable packaging circulating in a reuse system.

Recyclability classes will become a filter for market access. The regulation introduces recyclability performance classes A/B/C according to the following logic:

  • 2030: class based on design-for-recycling criteria.
  • 2035: recycling assessment added, meaning evaluation of whether a specific packaging category is actually recycled in sufficient volumes.
  • 2038: only class A or B packaging may be placed on the market; class C is removed from the market.

The thresholds are defined by the proportion of recyclable mass: class A requires ≥95% of mass to be recyclable, class B requires ≥80%, and class C requires ≥70%. Packaging where recyclable mass falls below 70% is considered technically non-recyclable. Recyclability is, however, a topic for which it is worth waiting for the delegated acts entering into force by 1 January 2028 at the latest, in which the Commission will establish the methodology for calculating design-for-recycling class rules. Mandatory minimum recycled (post-consumer) material content requirements will apply to the plastic components of plastic packaging as follows:

  • 2030: e.g. 30% for contact-sensitive PET (excluding single-use beverage bottles), 10% for other contact-sensitive plastics, 30% for beverage bottles, 35% for other plastic packaging.
  • 2040: targets increase (e.g. 50%/25%/65%/65%).

What do the changes mean in practice?

Packaging must be less cosmetic and more functional. Under the regulation, packaging becomes a functional means and the option to use it to add perceived brand volume disappears. For example, increasing perceived volume through double walls, raised bases, or similar devices is no longer permissible except for functional reasons. Similarly, the creation of empty space in grouped and transport packaging, including in e-commerce, is expected to decrease. Businesses must be prepared to demonstrate reuse and refilling, but the first reporting year for calculating and reporting the corresponding targets is only 2030.

Recyclability will denote a specific class and is no longer a slogan. Classes A/B/C are assessed per packaging unit by mass, and very practical factors are considered: whether components can be separated, the efficiency of sorting and recycling (yield/recovery rate), technological developments, and whether the resulting secondary raw material retains its functionality (substituting primary material). This means very concretely that the total mass of the packaging unit (all components combined) is taken, and the proportion of that mass qualifying under design-for-recycling criteria is calculated. Simply put, the formula used is: recyclable mass share (%) = (sum of mass of components deemed recyclable / total mass of packaging unit) × 100.

The denominator is the total mass of the packaging unit (excluding the product), meaning all packaging components present when the unit is placed on the market are taken into account:

  • primary material (e.g. bag/bottle/box/film),
  • closures/caps/lids,
  • labels/sleeves,
  • adhesives, coatings/interlayers,
  • other accessories (e.g. valve, handle, staples).

The numerator is the portion of the packaging unit’s mass deemed recyclable under design-for-recycling criteria. In practice, the following are among the factors considered in recyclability assessment:

  • whether the component is separable (by the consumer or the processing company),
  • the efficiency of sorting and recycling (yield/recovery rate),
  • whether the component does not impede the recycling of other material streams, and whether the resulting secondary raw material is of sufficient quality.

The cost of implementing the regulation depends on a company’s ability to apply life cycle assessment.

The regulation emphasises in several places that environmental benefits must be viewed using a life cycle approach — particularly in the context of reuse and refilling. In practice, applying life cycle analysis early helps with three things that reduce potential future costs:

  1. Avoiding potential errors at the design stage. For example, switching to a mono-material may raise the recyclability class but simultaneously change the mass of the packaging, its transport impact, or product shelf life. Life cycle assessment makes these trade-offs visible early.
  2. Identifying the 20% of changes that deliver 80% of the gain. The recyclability class logic accounts for component separability, sorting efficiency, and similar factors — and in this context, it is often small details such as labels, adhesives, additional film, or strapping that reduce the recyclable mass share.
  3. Documenting decisions in a way that builds credibility with the supply chain and customers. The regulation places the focus for conformity assessment and document collection on the producer and assumes that suppliers will provide the necessary data and documentation.

Companies that begin organising the data required for life cycle calculations today will get ahead of competitors from the start, since the same dataset can also be used for conformity assessment in the supply chain and for sustainability verification.

Conclusion.

The Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR) effectively makes packaging a component of the product, subject to progressively tightening market access requirements over time (classes, recycled content, minimisation, refilling). The good news is that the least costly part of preparation is organising the data and establishing the decision-making methodology. If this is in place by 2026, the design changes required between 2027 and 2030 will be manageable, well-justified, and considerably less painful.