Europe - Packaging Regulation (EU) 2025/40 (PPWR)

​Dear all,

On January 22, 2025, the European Union published the new Packaging Regulation (EU) 2025/40 (PPWR) in the Official Journal of the European Union.
The Regulation amends Regulation (EU) 2019/1020 and Directive (EU) 2019/904 and repeals Directive 94/62/EC, implies a substantial alteration in our approach to product compliance, specifically pertaining to packaging and waste management.

The PPWR introduces a mandatory Conformity Assessment for packaging that culminates in an EU Declaration of Conformity (Annex VIII).

A key section to focus on is Article 12, which outlines the blueprint for future packaging labeling requirements. The European Commission has been tasked with presenting implementing acts by August 12, 2026, to establish a harmonized labeling system.
These requirements extend to the specifications and formats for packaging labels, including those generated by digital means.
If the packaging contains Substances of Concern (SoC) as defined by the EcoDesign Framework Regulation (EU) 2023/1542, this must be indicated using standardized and open digital labeling technology, as will be defined in the forthcoming implementing acts.

As seen with other directives, such as the Battery Regulation (EU) 2023/1542, numerous additional implementing acts are foreseen. The timely identification of these acts will necessitate detailed and ongoing legal monitoring.

The Packaging Regulation will officially be enacted 20 days following publication, which sets the effective date as February 11, 2025. Here are key dates we must all be aware of:
•    The regulation takes effect on August 12, 2026, directly applicable in all Member States.
•    The revision of Article 67 (5), tied to the Single-Use Plastics Directive (EU) 2019/904, will not apply until February 12, 2029.
•    Certain aspects of the former Packaging Directive (94/62/EC) will remain valid until the new implementing acts are released, or until December 31, 2029, as referenced in Article 70 of the PPWR.
•    Decision 97/129/EC, concerning the identification system for recycling codes, will be repealed as of August 12, 2028. Its content will be integrated into a prospective implementing act.

For a deeper dive into the full legal text and implications, please refer to the attached files or link provided above.