EU Regulation 2025/40 on packaging and packaging waste (known as the PPWR, Packaging and Packaging Waste Regulation) structurally redefines how companies design, use and manage packaging in the European market.
It is not an interpretable directive or a technical recommendation: it is a directly applicable and binding rule in every Member State, with effects on product design, procurement, logistics, ESG reporting and regulatory compliance. It entered into force on 11 February 2025 and has applied, in general terms, since 12 August 2026.
The European legislator's message is unmistakable: the packaging waste problem is corrected at source. That is why the regulation shifts the focus from waste management towards ecodesign, reduction, reuse and data traceability. Below we analyse exactly what it requires, which companies it affects, the deadlines it imposes and how to prepare without last-minute improvisation.
What is EU Regulation 2025/40 and why is it a structural change?
EU Regulation 2025/40 governs the entire life cycle of packaging, from its design to its conversion into waste. Unlike the previous framework (Directive 94/62/EC), it removes regulatory fragmentation between Member States and sets harmonised technical criteria across the whole European Union. Its core objectives are:
- Effectively reduce the generation of packaging waste (a reduction target of 5% by 2030, 10% by 2035 and 15% by 2040 compared with 2018).
- Ensure that all packaging placed on the market is recyclable through design criteria.
- Eliminate unnecessary packaging and overpackaging.
- Guarantee full traceability of material and waste.
In practice, this means that poorly designed packaging is no longer legal, even if theoretical recycling infrastructure exists. Compliance no longer depends on intent, but on technical and documentary verifiability.
Which companies does EU Regulation 2025/40 affect?
The answer is direct: it affects any company that places packaging on the European market. The regulation applies to organisations that:
- Market packaged products in the EU.
- Import packaged products from third countries.
- Use industrial, commercial or household packaging.
- Design, manufacture, distribute or condition packaging.
There are no size-based exclusions: SMEs have adapted obligations, but they do not fall outside the scope. The regulation also connects with the extended producer responsibility that in Spain is already regulated by Royal Decree 1055/2022.
Sectors with the greatest impact
Although it is cross-cutting, the impact is especially relevant in food and drink, cosmetics and personal care, pharmaceuticals, retail and e-commerce, logistics and distribution, and manufacturing. In e-commerce, for example, overpackaging goes from being a bad practice to a legal breach, which forces a redesign of entire logistics processes, not just the final packaging.
What already applies and what comes later
Since 12 August 2026, the enforceable requirements include conformity assessment and the packaging technical documentation, packaging identification and manufacturer information, the minimisation of substances of concern and heavy-metal limits. The major design requirements (recyclability, recycled content, reuse, empty space) are concentrated in 2030 and later.
Design of recyclable packaging
The regulation sets precise technical criteria to determine whether packaging is recyclable at industrial scale, which means removing incompatible material combinations, non-separable multilayer packaging and elements that hinder automated sorting. Recyclability stops being a marketing claim and becomes a verifiable technical requirement.
Mandatory reuse targets
The regulation imposes minimum reuse quotas in specific sectors, especially in drinks and in transport and grouped packaging. They are measured by the percentage of units placed on the market, not by voluntary initiatives.
Reduction of packaging and elimination of overpackaging
The rule expressly prohibits unjustified empty volumes, double packaging without a technical function and non-functional decorative elements. It also sets a maximum empty-space limit of 50% in grouped, transport and e-commerce packaging.
Minimum recycled content
Certain packaging types must incorporate minimum percentages of recycled material, especially in plastics, demonstrable through verifiable documentation. This directly affects supplier contracts, raw-material certificates and material traceability systems.
Harmonised labelling
All packaging will have to include consistent information on waste separation, material type and instructions for the consumer, removing the coexistence of national symbols.
Restrictions on substances of concern
The regulation restricts the presence of PFAS substances (so-called "forever chemicals") above certain thresholds in food-contact packaging. It is one of the requirements that already apply.
Registration, traceability and reporting
Companies must keep detailed records of volumes placed on the market, the weight, material and function of each packaging unit, the degree of recyclability and reuse, and auditable documentary evidence. This requirement connects directly with ESG reporting and the CSRD: you can go deeper in the future of ESG reporting with AI.
Application timetable: what applies and when
The regulation already applies, but its obligations are staggered over time. As of August 2026, these are the key milestones:
| Date | Main obligation |
|---|---|
| 11 February 2025 | Entry into force of the regulation |
| 12 August 2026 | General application: most provisions already apply, including technical documentation, packaging identification and substance restrictions |
| 2030 | All packaging must be recyclable by design; reuse targets for certain formats; 5% waste reduction; minimum recycled content in plastics; 50% empty-space limit |
| 2035 | Packaging must be recyclable "at scale", with real collection and recycling infrastructure; 10% waste reduction |
| 2040 | More demanding recycled-content percentages; 15% waste reduction |
Waiting for the final milestones multiplies costs and legal risks. Companies that act early turn compliance into a competitive advantage.
Direct link with the CSRD and ESG reporting
EU Regulation 2025/40 cannot be managed in isolation: packaging and waste data feed key indicators of the CSRD, especially on circular economy and resource use (ESRS E5). Companies that integrate packaging, waste and ESG reporting into a single digital system reduce the audit effort and improve data quality.
How to prepare effectively
Identify all your real packaging
Generic categories are not enough: you have to identify each packaging unit separately, including secondary and tertiary packaging, with its exact weight, material and function.
Assess technical compliance
Each packaging unit must be analysed against recyclability, reuse and reduction criteria. Many apparently compliant packages do not pass this analysis.
Digitise data management
Spreadsheets cannot withstand complex audits or constant regulatory change. Digitalisation brings traceability, consistency and fewer errors, especially when the data is reused for the CSRD.
Frequently asked questions about EU Regulation 2025/40
When does EU Regulation 2025/40 apply from?
It entered into force on 11 February 2025 and has applied in general terms since 12 August 2026, with additional obligations staggered up to 2030, 2035 and 2040.
Does it replace Spanish packaging legislation?
As a regulation, it is directly applicable and prevails over national rules in what it governs. It coexists with national obligations such as the extended producer responsibility of Royal Decree 1055/2022.
Does it affect companies that only sell online?
Yes. E-commerce is one of the regulation's main focus areas because of overpackaging and empty space.
What happens if a company does not comply?
It is exposed to financial penalties, withdrawal of products from the market and loss of commercial access.
If your organisation needs an integrated view of packaging, waste and circular economy, a waste management platform that connects this data with your sustainability reporting is the most effective way to face the next milestones without risks.
