Regulation (EU) 2025/40 on packaging and packaging waste marks a significant shift. Rather than focusing primarily on what happens to packaging after use, it introduces a framework that covers the entire life cycle: design, materials, volume, reuse, recyclability, labelling and the responsibilities of those who produce and sell it.
For a long time, the conversation about packaging was largely confined to what happens after the consumer is done with it: separate collection, recycling, disposal, material recovery. These things matter, and they still do, but they are no longer enough to address the full scale of the problem. The sheer volume of packaging placed on the market, the complexity of the materials used, the spread of single-use formats and the growth of consumption models built around convenience, delivery and over-packaging have made one point impossible to ignore: not everything that is produced can be fixed at the end of the line.
Regulation (EU) 2025/40 responds to this reality. It sets sustainability and labelling requirements for packaging across its entire life cycle; from production and use through to waste management. Its aim is not only to improve recycling, but to eliminate unnecessary packaging, encourage reuse and refill, and harmonise national rules to keep the internal market functioning consistently.
The Regulation entered into force on 11 February 2025 and will generally apply from 12 August 2026. From that date, the new framework becomes a set of binding obligations for businesses, producers, distributors, online platforms, collection systems and public authorities alike.
The choice of a regulation rather than a directive, as was the case with the 1994 legislation, is itself significant. A regulation applies directly in all member states without needing to be transposed into national law. This matters in a sector where goods, materials and packaging cross borders, markets and supply chains every day.
The most important change concerns design. The new rules do not treat packaging as an afterthought, something to be assessed only when it becomes waste. Packaging must be designed from the outset to minimise harmful substances, reduce weight and volume without losing functionality, and be genuinely recyclable. From 2030, a system of recyclability performance classes will apply. By 2035, recyclability must be demonstrable in practice, through real collection, sorting and recycling systems.
This fundamentally changes what packaging is expected to be. It can no longer be judged purely on its ability to protect, transport or sell a product. It must also account for what it leaves behind; the materials it contains, how they can be separated and processed, whether they are compatible with collection systems, and whether any components make recovery difficult. Commercial function and environmental impact can no longer be treated as separate considerations.
One of the most consequential provisions concerns excess packaging. Packaging must be designed to minimise weight and volume while maintaining its function. The fact that consumers accept it, or that it helps sell a product, is no longer a justification for unnecessary bulk. This directly addresses the grey area where packaging stops serving a genuine purpose and becomes instead a marketing device, a visual amplifier or layers of material that are hard to justify. The Regulation also promotes reuse and refill, introducing requirements for reusable packaging and steering certain sectors away from single-use models. The European Commission explicitly references the goals of encouraging reuse and refill systems, strengthening deposit return schemes and restricting certain single-use plastics.
While plastic remains the most sensitive material, the rules apply to all packaging and all packaging waste, regardless of material or origin, whether industrial, commercial, domestic or retail. This breadth is necessary. The problem is not one material but an entire system that produces, distributes and discards enormous quantities of wrapping, containers and protective packaging. The Commission notes that in the EU, 40% of plastic and 50% of paper used goes into packaging. Half of marine litter comes from packaging. In 2022, 186.5 kg of packaging waste were generated per person in the EU.
The answer is not to swap one material for another. It is to eliminate what is unnecessary, make what remains truly recyclable, encourage reuse wherever possible and ensure that labelling helps consumers make the right choices. Not as a compliance box to tick, but as a practical tool for disposal, return or separation of materials.
For businesses, 2026 is not simply a matter of updating pack designs. Packaging becomes a question of regulatory compliance and industrial responsibility: it requires decisions about materials, volume, recyclability, recycled content, documentation and the consistency between environmental claims and what can actually be verified. EUR-Lex notes that plastic packaging will need to contain minimum percentages of recycled material recovered from post-consumer plastic waste, with some exceptions for pharmaceutical packaging, medical devices and dangerous goods transport.
For aquatic ecosystems, the connection is direct. Packaging is among the most common components of waste that reaches rivers, lakes and the sea, carried by wind, rain, surface runoff and urban drainage. Addressing it upstream means reducing a major source of pressure before it shows up on a riverbank, a beach or the seabed. Prevention does not begin with teaching people to sort their recycling. It begins with how objects are made and how much material is allowed to circulate in the first place.
Regulation (EU) 2025/40 is not a technical document for packaging specialists. It is one of the ways in which Europe is trying to bring the consumption of materials within a framework that is more measurable, more honest and less wasteful. Whether it works will depend on enforcement, on businesses acting ahead of deadlines, and on the strength of national collection and reuse infrastructure. But the principle is now fixed: packaging is not sustainable because it says so. It is sustainable because it is designed to be, and because that can be proved.