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

  1. List the countries where you sell to private individuals.
  2. 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.
  3. 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.
  4. Heavy metals (lead, cadmium, mercury, chromium VI): 100 mg/kg at most, all together (article 5, § 4).
  5. 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.

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