On 19 December 2024, the European Parliament and the Council formally adopted the Regulation (EU) 2025/40, an ambitious legislative piece that replaces the historic Directive 94/62/EC. Unlike its predecessor, this regulation has the nature of Regulations, which ensures direct, uniform and harmonised application in all Member States, eliminating distortions in the internal market caused by divergences in national transpositions.
This new legal framework responds to a critical statistical reality: packaging represents 36 % of municipal solid waste and 40 per cent of the % plastics used in the European Union. The aim is clear: to contribute to the Climate neutrality by 2050 y consolidate a real circular economy through the waste hierarchy.
Sustainability at the source: chemical restrictions and ecodesign.
The regulation introduces mandatory sustainability criteria that impact from the packaging design phase. One of the most relevant measures is the Restriction of Hazardous Substances. From the 12 August 2026, the introduction onto the market of food contact materials containing perfluoroalkyl and polyfluoroalkyl substances shall be prohibited (PFAS) above the set technical limits. Likewise, the limit of 100 mg/kg for the sum of heavy metals (lead, cadmium, mercury and hexavalent chromium).
Regarding the design, it is proposed Packaging minimisation. For the 1 January 2030, manufacturers shall ensure that the weight and volume of their packaging are reduced to the minimum functional level necessary to guarantee the safety and protection of the product. Packaging with double walls, false bottoms or unnecessary layers intended to increase the visual perception of the product's volume is expressly prohibited.
Recyclability and mandatory recycled content.
the regulations state that, to the 1 January 2030,
the 100 % of packaging placed on the market must be recyclable.
Recyclability will be assessed using a grading system (A, B or C):
• Grade A, B or C minimum requirement for commercialisation
from 2030 (minimum recyclability rate of 70 %).
• Grade A or B: mandatory from 2038
(minimum performance of 80 %).
To boost the secondary raw materials market, mandatory minimum percentages are set for Post-consumer recycled plastic by 2030: an 30 % for PET bottles and contact lenses, and a 35 % for other plastic packaging.
Logistics optimisation and waste prevention.
Operators using collective, transport or e-commerce packaging must ensure that the the void ratio must not exceed 50 % from 2030. Space filled with materials such as plastic bubbles or polystyrene will be counted as void.
Furthermore, the regulation prohibits specific single-use formats from 2030, including:
Plastic packaging for fresh fruit and vegetables under 1.5 kg.
• Single-dose formats in the HORECA sector.
Miniature toiletries and amenity packaging in the accommodation sector.
Reuse and refilling: new business models.
The text strongly encourages the transition towards reuse systems. Economic operators in sectors such as transport, e-commerce, and beverages will need to achieve specific quantitative targets for reusable containers from 2030 onwards. For example, 40 % of the transport packaging used must be reusable by that date.
In the HORECA channel, starting from February 2027, takeaway food establishments must allow customers to use their own containers, offering them conditions no less favourable than if they used single-use packaging.
Governance: labelling, registration and producer responsibility.
To ensure traceability and the correct separation of waste, a Harmonised System or HS coding system based on pictograms for 2028. Packaging must be labelled to match those on public waste bins.
The Extended Producer Responsibility (EPR) is reinforced. It It is mandatory for all producers to register with the national registry from each member state where it markets its products before 12 August 2026. Los pagos a los sistemas de recuperación y reciclaje de envases (SCRAP) estarán sujetos a una tasa. eco-modulation based on the degree of recyclability (A, B or C) and recycled content, rewarding superior environmental performance.
- Cómo prepararse: hoja de ruta para la conformidad.
- Determine the legal role and carry out a diagnosis of the packaging portfolio.
- Conduct an immediate chemical audit (PFAS and heavy metals).
- Ensure compliance with the RAP by country and registration in national registries.
- Technical file preparation and EU declarations of conformity.
- 2030 Ecodesign Planning (Minimisation and Recyclability).
- To define a content repurposing and reuse strategy.
EN 
ES 
CA 
FR