EU Regulation 2025/40 on Packaging: requirements and obligations for companies

EU Regulation 2025/40 on packaging and packaging waste fundamentally reshapes how companies design, use, and manage packaging within the European market.

It is neither an interpretable directive nor a technical recommendation: it is a directly applicable and binding regulation with immediate effects on product design, procurement, logistics, ESG reporting, and regulatory compliance.

The message from the European legislator is unequivocal: the packaging waste problem must be addressed at the source. For this reason, the regulation shifts the focus away from waste management and toward eco-design, reduction, reuse, and data traceability.

Companies that fail to adapt their operational and information strategies will face sanctions, product withdrawals, and loss of market access.

Below, we analyse exactly what EU Regulation 2025/40 requires, which companies it affects, the timelines it establishes, and how to prepare efficiently without last-minute improvisation.

What is EU Regulation 2025/40 and why does it represent a structural change?

EU Regulation 2025/40 governs the entire life cycle of packaging, from design to its conversion into waste.

Unlike the previous framework, it eliminates regulatory fragmentation between Member States and establishes harmonised technical criteria applicable throughout the European Union.

The objectives of this regulation are to:

• Effectively reduce the generation of packaging waste.
• Ensure that all packaging placed on the market is recyclable or reusable.
• Eliminate unnecessary packaging and overpackaging.
• Guarantee full traceability of materials and waste.

In practice, this means that poorly designed packaging becomes illegal, even if theoretical recycling infrastructure exists. Compliance no longer depends on intent, but on technical and documentary verifiability.

Which companies are affected by EU Regulation 2025/40?

The answer is straightforward: any company that places packaging on the European market.

The regulation applies to organisations that:

• Market packaged products in the EU.
• Import packaged products from third countries.
• Use industrial, commercial, or household packaging.
• Design, manufacture, distribute, or condition packaging.

There are no size-based exclusions. SMEs have adapted obligations, but they are not exempt from the scope of application.

Sectors with the highest regulatory impact

Although the regulation is cross-cutting, its impact is particularly significant in:

• Food and beverages.
• Cosmetics and personal care.
• Pharmaceuticals.
• Retail and e-commerce.
• Logistics and distribution.
• Manufacturing industry.

In e-commerce, for example, overpackaging shifts from being a bad practice to a legal non-compliance, forcing a redesign of entire logistics processes, not just the final packaging.

What obligations does EU Regulation 2025/40 impose on companies?

Mandatory design of recyclable packaging

The regulation establishes precise technical criteria to determine whether packaging is recyclable at an industrial scale. This requires the elimination of:

• Incompatible material combinations.
• Non-separable multilayer packaging.
• Elements that hinder automated sorting.

Recyclability ceases to be a marketing claim and becomes a verifiable technical requirement. Design decisions therefore acquire direct legal implications.

Introduction of mandatory reuse targets

EU Regulation 2025/40 imposes minimum reuse quotas in specific sectors, particularly logistics, transport, and beverages. These quotas are measured as a percentage of units placed on the market, not through voluntary initiatives.

Mandatory reduction of packaging and elimination of overpackaging

The regulation explicitly prohibits:

• Unjustified empty space.
• Double packaging without a technical function.
• Non-functional decorative elements.

This turns material reduction into a legal requirement rather than a sustainability recommendation. Less packaging means lower costs, less waste, and reduced regulatory risk.

Minimum recycled content requirements

Certain types of packaging must include minimum percentages of recycled material, especially plastics. These percentages must be demonstrable through verifiable documentation, directly affecting:

• Supplier contracts.
• Raw material certificates.
• Material traceability systems.

Without a robust data system, compliance is unfeasible.

Harmonised labelling across the EU

All packaging must include clear and harmonised information on:

• Waste separation.
• Material type.
• Consumer-friendly disposal instructions.

This eliminates the coexistence of national symbols, reducing confusion and improving collection efficiency.

Registration, traceability, and mandatory reporting

Companies must maintain detailed records of:

• Volumes of packaging placed on the market.
• Weight, material, and function of each packaging unit.
• Degree of recyclability and reuse.
• Auditable documentary evidence.

This requirement is directly linked to ESG reporting and the CSRD. You can read more in our article: The future of ESG reporting: integrating financial and non-financial data with AI.

Implementation timeline of EU Regulation 2025/40: when each obligation applies

Although the regulation entered into force in 2025, the initial years focus on design, labelling, and traceability. Reuse targets follow, and finally the obligation that 100% of packaging be recyclable comes into effect.

Waiting until the final milestones multiplies costs and legal risks. Companies that act early turn compliance into a competitive advantage.

Direct link to the CSRD and ESG reporting

EU Regulation 2025/40 cannot be managed in isolation, as packaging and waste data feed key CSRD indicators, particularly in circular economy and resource use.

At Manglai, we observe a clear pattern: companies that integrate packaging, waste, and ESG reporting into a single digital system reduce audit effort by up to 40% and significantly improve data quality.

How to prepare effectively for EU Regulation 2025/40

Identify all actual packaging

Generic categories are insufficient. Each packaging unit must be identified individually, including secondary and tertiary packaging, with exact weight, material, and function.

Assess technical compliance

Each packaging unit must be analysed against recyclability, reuse, and reduction criteria. Many apparently “compliant” packages fail this technical assessment.

Digitise data management

Spreadsheets cannot withstand complex audits or constant regulatory change. Digitalisation enables traceability, consistency, and error reduction, especially when data is reused for CSRD reporting.

EU Regulation 2025/40: packaging as a strategic variable

EU Regulation 2025/40 transforms packaging into a strategic business variable rather than a secondary operational element.

Companies that act now reduce costs, minimise risks, and gain efficiency. Those that delay adaptation will face sanctions, urgency, and loss of competitiveness.

If your organisation needs an integrated view of packaging, waste, circular economy, and ESG reporting, our blog offers a practical roadmap based on real experience with industrial and service companies.

FAQs about EU Regulation 2025/40

Does EU Regulation 2025/40 replace Spanish packaging legislation?‍

Yes. As a regulation, it is directly applicable and prevails over national legislation.

Does it affect companies that sell exclusively online?‍

Yes. E-commerce is one of the regulation’s main focus areas due to overpackaging.

Are external audits required?‍

In many cases, yes, especially when data is integrated into ESG or CSRD reporting.

What happens if a company does not comply with EU Regulation 2025/40?‍

Non-compliance can result in financial penalties, product withdrawal from the market, and loss of commercial access.

Is it mandatory to digitise packaging management?‍

Not explicitly, but without digitalisation, sustained compliance is practically impossible.