Luxembourg: The Packaging and Packaging Waste Regulation, adopted in December 2024 and entered into force on 11 February 2025, applies across the European Union from 12 August 2026. With the deadline approaching, the Commission published a comprehensive guidance document and a set of frequently asked questions on 30 March 2026 to help manufacturers, importers, distributors and online operators interpret obligations that span the full packaging life cycle from design to disposal.
Regulation 2025/40 replaces a 1994 directive that operated through national transposition and produced fragmented rules across the single market. The new instrument applies directly in all 27 Member States. Its substantive core requires that all packaging placed on the EU market be recyclable by 1 January 2030, with a system of recyclability performance grades that becomes operational from that date and stricter obligations phased in from 2038. The regulation prohibits specific single-use plastic packaging formats — for fruit and vegetables, condiments in the HORECA sector, small toiletries used in accommodation, and very lightweight plastic bags except for hygiene or food-waste prevention.
Minimum recycled content targets for plastic packaging tighten progressively through 2030 and 2040, with limited exceptions for pharmaceutical packaging, infant food packaging, medical devices, hazardous goods transport and compostable plastics. The packaging minimisation rule, applicable from 2030, requires that grouped, transport and e-commerce packaging not exceed a 50 per cent empty-space ratio. Marketing considerations and consumer acceptance no longer justify additional packaging weight or volume — a clause that targets the practice of designing oversized boxes to suggest greater perceived product value.
Extended producer responsibility sits at the centre of the financial architecture. Producers bear the costs of collection, sorting, recycling and disposal of the packaging they place on the market, with fees modulated according to recyclability grades, recycled content, reusability and the presence of substances of concern. Financial contributions apply from eighteen months after the entry into force of the relevant delegated and implementing acts that will set the technical parameters. Member States must ensure that EPR schemes cover all packaging types and that fee structures are transparent.
Member States must achieve packaging waste reductions of 5 per cent by 2030, 10 per cent by 2035 and 15 per cent by 2040, all measured against 2018 baselines. Separate collection targets are tightened, with an exemption available to Member States that already exceed an 80 per cent collection rate in 2026 and submit a credible implementation plan toward the 90 per cent overarching target.
Labelling requirements introduce a digital code — typically a QR code — that allows consumers and waste operators to retrieve information on reusability and to track packaging through its life. Manufacturers must issue an EU Declaration of Conformity confirming compliance with sustainability and labelling requirements. The economic operator filling the packaging and making it available on the market for the first time is the producer for EPR purposes, a definitional choice that significantly affects supply chain accounting for cross-border e-commerce.
The regulation sits alongside the broader Circular Economy Action Plan and complements the Ecodesign for Sustainable Products Regulation and the Batteries Regulation. The Commission has flagged 2026 as the year to advance a Circular Economy Act, with end-of-life criteria for mechanical recyclate and new customs codes for imported recycled materials. Audits of recycling installations outside the EU will verify that imports described as recycled PET genuinely meet European standards, addressing a long-running concern about a level playing field for domestic recyclers.
The export of plastic waste to non-OECD countries will be banned from November 2026. Industry estimates that without end-of-waste criteria for plastics, the European recycling sector faces additional costs of approximately 120 million euros annually, equating to around 260,000 euros per recycler. By the Commission’s projection, full implementation of the regulation alongside related instruments could reduce plastics value chain emissions by approximately 80 million tonnes of CO2 equivalent per year and improve the trade balance by 18 billion euros by 2050.




