New EU packaging rules explained

Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC

Update

New European Union (EU) rules on packaging and packaging waste, including design and waste management, are set by the packaging and packaging waste Regulation 2025/40 (PPWR).

This Regulation aims to:

• avoid and reduce packaging waste, and stimulate reuse
• make all packaging on the EU market recyclable in an economically viable way
• increase the recycling of packaging materials, especially plastic, and their reuse.

The new rules set stricter sustainability, labelling, and conformity requirements on all food packaging, which will also apply to suppliers of packaged food to the EU market who are based outside the EU. Some key requirements are as follows.

• All packaging must be recyclable by 2030. Plastic packaging must contain minimum amounts of recycled plastic, packaging must be minimised (by weight and volume), and contaminants must be reduced. Producers of recycled plastic in non-EU countries must produce it in a way that is equivalent to EU standards for the collection of plastic and environmental emissions.
• There will be new limits on concentrations of substances of concern in packaging, including per- and polyfluorinated alkyl substances (PFAS).
• Certain packaging materials will be banned, including single use plastic packaging for quantities of certain fresh fruit and vegetables <1.5 kg. All sticky labels attached to fruit and vegetables, and single use tea and coffee bags, will have to be (at least) industrially compostable.
• Documentation demonstrating compliance with new requirements must be passed along the supply chain.

These rules will apply from different dates (see Table 1).

The key PPWR provisions are presented in the video and slides of a webinar (European Commission 2024) to help stakeholders prepare for the new rules.

What is changing?

Overview

Scope

The PPWR establishes rules for all packaging and packaging waste made of any material, including the following (Art. 3 of the new Regulation):

• primary production packaging: packaging for unprocessed products
• sales packaging: packaging of goods sold to the final consumer
• grouped packaging: packaging that groups a number of products (for convenience) at the point of sale
• transport packaging: packaging that facilitates the handling and transport of products, including e-commerce packaging, but not including road, rail, ship, or air containers
• disposable tea, coffee, or other beverage bags or single-serve units.

The PPWR also establishes comprehensive rules on waste management at the level of EU Member States, prevention of packaging waste, and promotion of reusable packaging on a global scale.

This AGRINFO explainer focuses on aspects of the Regulation most relevant to non-EU suppliers of agri-food products.

Key obligations for packaged food from non-EU countries

Under the PPWR (Art. 18), packaging and packaged food exported from non-EU countries to the EU must:

• comply with the sustainability requirements set out in Arts. 5–11
• be correctly labelled
• be accompanied by the correct documentation
• be correctly identified
• have undergone a conformity assessment.

From 1 January 2030, the Regulation (Art. 25) forbids single use plastic packaging (for example, nets, bags, trays, containers) for quantities of certain fresh fruit and vegetables below 1.5 kg. Exceptions allowing continued use of some of these packaging formats could be introduced at later stages, but this has yet to be fully clarified. Currently, the PPWR indicates that exceptions may be introduced both at EU level (i.e. for all EU countries) and at EU Member State level (i.e. only for specific EU countries):

• by 12 February 2027, the EU will publish a (non-exhaustive) list of exceptions where some of these packaging formats may still be used
• by 1 January 2030, EU Member States could additionally authorise other single use plastic packaging for certain fresh fruits and vegetables below 1.5 kg.

See Figure 1 for more information.

Complementary implementing rules

As a Regulation, the PPWR will be directly and uniformly applied by EU Member States (without needing to be incorporated into national law). However, many (new) requirements of the PPWR will be detailed in additional texts that are not yet published. These texts will establish guidelines, methodologies, criteria, standards, etc., and will set complementary rules and/or exceptions to support uniform application of the PPWR rules. AGRINFO will provide updates on implementation of the PPWR as soon as information becomes available.

Sustainability requirements

Under the new rules, all prepackaged food imported into the EU will have to fulfil the sustainability requirements set out in Arts. 5–11 of the PPWR, including the following.

Substances of concern (Art. 5)

The PPWR sets limits for two groups of substances to minimise their presence in packaging:

• the sum of concentration levels of lead, cadmium, mercury, and hexavalent chromium must not exceed 100 mg/kg (currently a requirement under Directive 94/62/EC)
• concentrations of PFAS in food contact packaging cannot exceed the levels shown in Table 2 (from 12 August 2026).

Recyclable packaging (Art. 6)

• From 1 January 2030, packaging must be recyclable so as to be used again as a raw material. This requires packaging to be designed for recycling and, once it becomes waste, to be collected separately.
• Packaging will be graded according to its recyclability performances: Grade A 95% recyclability; Grade B 80%; Grade C 70% (Table 3 in Annex II of the PPWR).
• From 1 January 2030, packaging with less than 70% recyclability cannot be sold on the EU market.
• From 1 January 2038, packaging will have to meet Grade A (95% recyclability) or B (80% recyclability) to be sold on the EU market.
• By 2028, the European Commission will adopt detailed rules on recycling criteria and recyclability performance grades for each type of packaging material, and on recyclability performance assessments (e.g. regarding quality, size, and functionality of packaging).
• Some types of packaging are exempted from these recyclability requirements (to be reviewed by the European Commission by 1 January 2035):
  • innovative packaging (i.e. that is not listed in Table 1 of Annex II of the PPWR), made from new materials that significantly improve its functions in an environmentally friendly way
  • pharmaceutical packaging, medical devices, diagnostic devices, infant formula, transport of dangerous goods.

Minimum recycled content in plastic packaging (Art. 7)

By 2030, plastic packaging must contain at least the minimum percentage of recycled plastic per unit of packaging, as shown in Table 3. More ambitious targets are set for 2040. The percentage targets do not apply to food packaging if the amount of recycled content would pose a threat to human health, to compostable plastic packaging, or where plastic represents less than 5% of the total weight of the whole packaging unit.

By 31 December 2026, the Commission will indicate a methodology to calculate the amount of recycled content. The plastic waste used in non-EU countries to make recycled plastic must be collected in a way that is equivalent to the EU standards for separate collection set out in the Single Use Plastics Directive (2019/904) and Waste Directive (2008/98/EC). Emissions into air, water, and land from installations that recycle plastics in non-EU countries must meet performance levels equivalent to those established for the EU in the Industrial Emissions Directive (2010/75/EU). By 31 December 2026, the Commission will develop a methodology for assessing and auditing the equivalence of recycling practices in non-EU countries.

Compostable packaging (Art. 9)

From 12 February 2028, single use bags for tea, coffee, and related beverages, and sticky labels attached to fruit and vegetables, must be industrially compostable in line with standards set by bio-waste treatment facilities. EU countries can additionally request these bags and sticky labels to be home compostable. European standardisation organisations will provide the technical specifications for both industrial and home compostable packaging. The current existing European standard for industrial composting (EN 13432:2000) can be used as guidance, but will no longer serve as proof of conformity (see Background).

Minimising packaging

The PPWR aims to reduce the size of all types of packaging. From 1 January 2030:

• packaging manufacturers must reduce packaging to the minimum volume/weight needed to ensure its functionality, avoiding unnecessary layers of packaging and misleading packaging (double walls, false bottoms, etc.) (Art. 10)
• operators who fill packaging on the EU market must reduce empty space to the minimum necessary (50% empty space ratio) (Art. 24).

Labelling and information requirements

Labelling (Art. 12)

From 12 August 2028, the following must be included on packaging:

• harmonised labels with pictograms providing information on the composition of packaging material, to help consumers sort recyclable materials (these labels will also be placed on waste containers) – this obligation applies to all types of packaging (including e-commerce packaging), with the exception of transport packaging
• for compostable packaging, a label that indicates if the packaging is not suitable for home composting and should not be discarded in nature
• for plastic packaging with minimum recycled content, a voluntary label with information on the proportion of recycled content and, where applicable, a QR code
• for reusable packaging (from 12 February 2029), a label showing its reusability.

Digital labels or QR codes on packaging can be used to:

• provide additional information on how to dispose of each separate packaging component
• accompany packaging containing substances of concern with information about their composition (name and concentration) (mandatory from 1 January 2030).

All these labels based on pictograms will be developed by the European Commission.

Environmental claims (Art. 14)

Messages about the positive or neutral environmental impacts of packaging (“environmental claims”, see Directive 2024/825) can be used where packaging exceeds the minimum sustainability requirements of the PPWR, and should clearly indicate if they apply to part or all of the packaging. The PPWR sets criteria, methodologies, and rules to calculate the packaging properties.

Restricted packaging formats

Some uses of packaging will not be permitted from 2030 (Art. 25 and Annex V). This includes a ban on single use plastic packaging for quantities of fresh fruit and vegetables <1.5 kg, such as nets, bags, trays, and containers.

In two specific cases, from 1 January 2030 individual EU countries may authorise single use plastic packaging for fresh fruit and vegetables <1.5 kg where:

• such packaging is needed to avoid water or other fluid loss, microbiological hazards or physical shocks, or oxidation
• there is no other way to separate organic and non-organic fruits and vegetables at the point of sale.

The Commission will provide more detailed guidelines by 12 February 2027, including a non-exhaustive list of authorised packaging for specific fruits and vegetables <1.5 kg. See Figure 1 for more information.

Conformity assessment

The PPWR sets different obligations for each operator along the supply chain: packaging manufacturer, producer, supplier, importer, distributor, authorised representative, final distributor (Art. 3).

As a general rule, all operators in the supply chain are responsible for sharing information to prove compliance with the PPWR requirements. This information must be passed along the supply chain.

Packaging manufacturers (Art. 3(13))

Packaging manufacturers in non-EU countries must comply with the PPWR if they:

• manufacture packaging or packaged products sold in the EU
• have packaging or packaged products designed or manufactured under their own name/trademark that is sold in the EU.

Non-EU manufacturers must comply with the PPWR obligations during the production of packaging until the packaged products are exported to the EU and their obligations are transferred to the EU importer.

Before exporting packaged products to the EU, packaging manufacturers must:

• assess the conformity of their packaging with the rules set in the PPWR (Art. 38)
• prepare an EU declaration of conformity (Art. 39 and Annex VIII)
• prepare technical documentation (Annex VII) with the following information:
  • general description of the packaging and its intended use
  • design and manufacturing drawings and materials of components
  • descriptions and explanations necessary to understand the drawings, schemes, and operation of the packaging
  • list of relevant technical standards applied
  • description of how assessments have been carried out for packaging recyclability, minimisation, and reusability
  • test reports.

For each packaged product, a single declaration of conformity needs to be continuously updated (in case of changes in packaging, legal requirements, etc.). When packaged products are imported into the EU, the declaration of conformity and other manufacturer’s obligations are transferred to the EU importer.

EU importers of non-EU packaged products must keep the technical documentation and declaration of conformity for a minimum of 5 years (single use) and 10 years (reusable) from the date when the packaging was placed on the EU market. This documentation must be passed along the supply chain and can be requested by EU Member State control authorities.

Manufacturers must clearly indicate on the packaging (or via a QR code or other data carrier) their name, registered trade name or trade mark, postal address, and (where available) electronic contact address (Art. 18).

Suppliers of packaging components (Art. 16)

Suppliers of packaging components must provide the information and documentation necessary for the manufacturer to prove the conformity of the packaging and the packaging materials.

Producers (Art. 3(15))

Operators based outside of the EU may have to comply with obligations set by the PPWR to packaging producers only if they sell packaging or packaged products directly to EU consumers or professional users for distribution, consumption, or use in an unchanged form (European Commission 2022a). The PPWR will not apply to non-EU producers if the EU buyers change the form of the packaged products (e.g. by removing transport packaging, processing, or incorporating into another product) and sell these products on the EU market. More information will be shared once the definition of producers for non-EU operators has been clarified.

Extended producer responsibility (Art. 45)

EU countries can individually request non-EU producers of packaged products to appoint an authorised representative for extended producer responsibility (EPR), who will carry out the obligations related to the management of packaging and of packaging waste in that country on behalf of the non-EU producer.

This is not a general obligation, but can be requested by an EU Member State when the non-EU producer makes packaging or packaged products available on their territory for the first time (even if is already on the market in other EU Member States). Each EU country will establish a producer register for the EPR scheme by the end of 2027 or beginning of 2028.

The EPR scheme aims to ensure that producers of products are financially and/or organisationally responsible for the management of the waste stage of a product’s life cycle, for example by organising or paying for the collection and disposal of waste (Directive 2008/98/EC, Art. 3(21)).

Why?

Packaging is one of the main users of virgin materials and is a significant contributor to waste. Increased use of packaging in recent years has contributed to CO₂ emissions, biodiversity loss, and pollution. The share of recycled packaging has grown significantly since 2012, but much recyclable packaging is not recycled in practice because suitable collection and recycling processes are not in place, or are not economically viable. The PPWR is part of the EU’s circular economy action plan (European Commission 2020b) that commits to making all packaging reusable or recyclable by 2030, and to reducing (over) packaging and packaging waste. This action plan is one of the main components of the European Green Deal agenda, which aims to cut greenhouse gas emissions while supporting economic growth.

Prior to the PPWR, packaging and packaging waste in the EU were regulated by Directive 94/62/EC. Because EU Directives set out goals that each EU Member States must achieve through national law, this Directive was implemented in different ways, particularly in response to the challenge of plastic packaging, and some EU countries failed to meet various objectives (EPRS 2022). Setting the new rules in a Regulation (rather than a Directive), which must be applied directly and uniformly across the Union by all EU countries, will reduce administrative burdens on businesses by aligning practices across EU countries.

An evaluation study (European Commission 2020a) identified the need to improve the essential requirements for packaging set in Directive 94/62/EC, which are no longer aligned with packaging technologies now available on the market, or with current environmental concerns.

Timeline

Regulation 2025/40 applies from 12 August 2026. However, the rules apply from different dates (see Table 1).

What are the major implications for exporting countries?

Importers of food products to the EU have to ensure that all packaged food imported into the EU must:

• have undergone the conformity assessment procedure carried out by the manufacturer (Art. 38), and have technical documentation demonstrating compliance with Arts. 5–11 (Annex VII)
• be labelled in accordance with Art. 12
• be accompanied by the required documents
• be correctly identified [Art. 15(5,6)].

Today, packaging that comes into contact with food must be produced in accordance with good manufacturing practice under Regulation 2023/2006. This requires setting up effective quality assurance systems, including documentation on specifications and manufacturing processes that must be presented to competent authorities on request. Packaging must also comply with Regulation 1935/2004 on food contact materials (see Food contact materials explained).

Because the PPWR goes beyond existing requirements, implications for non-EU businesses supplying the EU market could include:

• more testing with additional costs for operators because of the requirement for manufacturers to report on substances such as PFAS (European Commission 2022b)
• an additional administrative burden on suppliers of packaged food, including exporters in non-EU countries, who have to produce and pass down the supply chain technical documentation that includes new sustainability information and a conformity declaration (European Commission 2022b)
• significant challenges for manufacturers of recycled plastic in non-EU countries to meet EU standards regarding collection of plastics and emissions into the environment (Politico 2024)
• insufficient supply of recyclable and recycled materials by the 2030 deadline (FoodDrink Europe 2023)
• added complexity for the fruit and vegetable sector due to the ban on single use plastic packaging for fresh fruit and vegetables in quantities <1.5 kg, potentially exacerbated by individual EU Member States creating exemptions from these rules (Freshfel Europe 2024).

The PPWR allows EU Member States to set higher targets for some obligations, and to choose not to apply some obligations in specific cases (for example, certain prepacked fresh fruit and vegetables <1.5 kg could be packaged in single use plastic packaging). The differences between the national applications of the rules within the 27 EU Member States will have to be closely monitored.

Recommended Actions

Under the new rules, non-EU exporters of packaged foods to the EU market must ensure by the end of 2025 that:

• any packaging has undergone an appropriate conformity assessment procedure
• the relevant technical documentation has been drawn up by the packaging manufacturer
• the manufacturer has provided a written declaration of conformity for the packaging type.

Suppliers exporting packaged foods should engage early with packaging manufacturers to review testing, monitoring, and documentation processes. Packaging manufacturers must be able to provide the information and documentation necessary for the exporter manufacturer to demonstrate compliance with this Regulation.

Exporters will need long-term strategies for sourcing packaging that can meet new recyclability criteria and, in the case of plastic packaging, for ensuring that recycled plastic is produced in a manner equivalent to EU standards.

Suppliers exporting packaged products who are considered as producers (because they sell products directly to an EU consumer or business for distribution, consumption, or use in an unchanged form) should monitor the national law of each EU country to verify if they must appoint an authorised representative for extended producer responsibility (EPR) in that country.

Suppliers of fruit and vegetables should closely monitor exemptions to the ban on use of single use plastic packaging for quantities of fresh fruit and vegetables below 1.5 kg (Annex V). This includes the non-exhaustive list of exemptions to be published by the European Commission by February 2027, and additional exemptions set by EU countries from January 2030.

Suppliers of fruit and vegetables should also explore sources of industrially compostable sticky labels, and potentially home compostable ones (if required by EU countries).

Background

Directive 94/62/EC aimed to prevent packaging waste through reusable packaging, recycling, and other forms of recovery. Reducing the final disposal of such waste contributes to the transition towards a circular economy. The Directive has been updated many times, incorporating requirements on plastic carrier bags (2015) and new recycling targets (2018).

Directive 94/62/EC established essential requirements related to the manufacturing and composition of packaging, and its reusability and recoverability (Annex II). Packaging producers were required to demonstrate compliance with these requirements by following European (CEN) Subject Standards (listed below) that will be replaced at a later date:

• EN 13427_2004: requirements for the use of European standards for packaging and packaging waste (the “umbrella standard”)
• EN 13428_2004: prevention by source reduction
• EN 13429_2004: reusable packaging
• EN 13430_2004: material recycling
• EN 13431_2004: energy recovery.

European standards are developed by officially recognised European standardisation organisations (CEN, CENELEC, and the European Telecommunications Standards Institute). They harmonise specifications to facilitate cross-border trade (within the EU and with non-EU partners). The national standardisation bodies or committees in each EU Member State must adopt each European standard as a national standard. Relevant national standards may be used to demonstrate compliance where no harmonised standards exist.

As Directive 94/62/EC is now being replaced by a Regulation, the PPWR will be directly and uniformly applied by EU Member States (without needing to be incorporated into national law).

Resources

Sources

Tables & Figures

Source: based on Regulation 2025/40

Source: based on Regulation 2025/40, Art. 5(5)

Source: based on Regulation 2025/40, Arts. 7(1,2)

Source: based on Regulation 2025/40, Annex V