Regulation (EU) 2025/40 reforms packaging; most of it has applied since 12 August 2026.
Who is concerned
- Any company that places packaging on the European market: manufacturer, importer, online seller. Packaging also means the box, the bag, the film, the shipping carton.
- The point that affects Asia: a seller who sells at a distance to private individuals in a European country must be registered as a packaging "producer" in the buyer's country (article 44), and have an authorised representative appointed in writing there (article 45, § 3).
- Online marketplaces must obtain, before accepting the seller, its registration number in the buyer's country and a statement that it meets its obligations, then check that this is complete and reliable (article 45, § 4 and § 6). Without this information, no more sales.
- Logistics companies that prepare orders must receive the same information (article 45, § 7).
What to do now
- List the countries where you sell to private individuals.
- Register in each one (national register of producers), directly or through an authorised representative. The registers are being set up country by country: ask the body in each country.
- Food packaging (tableware, boxes, bags): since 12 August 2026, it must not exceed the limits for PFAS ("forever chemicals"): 25 ppb for one PFAS, 250 ppb for the sum, 50 ppm for all PFAS, polymers included (article 5, § 5). Ask your supplier for the test reports.
- Heavy metals (lead, cadmium, mercury, chromium VI): 100 mg/kg at most, all together (article 5, § 4).
- Keep the evidence: registration numbers, mandates, test reports.
To watch: a simplification proposal. In December 2025, the European Commission proposed to suspend the obligation to have an authorised representative for direct sales to consumers in other European countries. It is a proposal under discussion, not a rule in force: check where it stands before signing or paying an authorised representative.
What comes next
- 12 August 2028 (at the latest, or 24 months after the implementing act if it comes later): a harmonised label with pictograms shows the packaging materials, to help sorting (article 12).
- 1 January 2030 (at the latest, or 3 years after the implementing act): no more than 50% empty space in grouped, transport and e-commerce packaging (article 24).
- 2030: target of recyclable packaging across the whole European market.
The traps
- Believing that a single registration is enough for the whole of Europe: it is one registration per country where you sell to private individuals.
- Forgetting the shipping carton and the padding: they are packaging too.
- Buying tableware or food boxes in Asia without a test report (see tableware and food contact).
Dates
- In force since 11 February 2025.
- General application: since 12 August 2026.
See also
Official source (consulted on 01/11/2026): Regulation (EU) 2025/40 — EUR-Lex (articles 5, 12, 24, 44, 45 and 71); European Commission Packaging page.
For information only: general information, not legal advice; it does not engage the liability of the Passerelle. Check with the official source, the body in your country or your adviser before deciding.