On 22 January 2025, Regulation (EU) 2025/40 on packaging and packaging waste was published in the Official Journal of the European Union, setting out requirements for the entire life cycle of packaging in terms of environmental sustainability and labelling, and coming into force from 12 August 2026.
The key points of Regulation (EU) 2025/40
• It is a very dense text, consisting in 188 explanatory “Whereas”, 13 chapters, 71 articles and 13 annexes… which replaces Directive 94/62/EC.
• It establishes requirements for the entire life cycle of packaging as regards environmental sustainability and labelling, as well as for the extended producer responsibility, collection, treatment and recycling of packaging waste.
• It applies to all packaging, regardless of the material used, and to all packaging waste, whether such waste is used in or originates from industry, other manufacturing, retail or distribution, offices, services or households.
• It comes into force on 12 August 2026, but contains a number of transitional provisions extending until 2040, punctuated by the scheduled publication of several implementing acts.
Chapter I - General provisions
This chapter details the purpose of the Regulation, its scope, and provides no fewer than 71 definitions (not counting those already included in other European texts and referred to).
Chapter II - Sustainability requirements
This chapter comprises 7 articles.
Substances in packaging (Article 5)
• Packaging shall be so manufactured that the presence and concentration of substances of concern, i.e. which affect human health or the environment, or that negatively …
