Introduction to the EU Packaging Regulation (EU) 2025/40

On January 22, 2025, the European Union published the Packaging and Packaging Waste Directive (EU) 2025/40 (PPWR) in its official gazette and abolished the Packaging Directive 94/62/EC. The regulation came into effect on February 11, 2025 and will be implemented from August 12, 2026. The following are the main contents of the Packaging Regulation (EU) 2025/40:

Requirements for restricted substances in packaging:
⑴ For all packaging: The total concentration of heavy metals (lead, cadmium, mercury and hexavalent chromium) shall not exceed 100 mg/kg.
⑵ Food contact packaging: As of August 12, 2026, perfluoroalkyl and polyfluoroalkyl substances (PFAS) must meet the following requirements:
a. The content of individual PFAS is less than 25 ppb (excluding polymer PFAS).
The total content of PFAS is less than 250 ppb (excluding polymer PFAS).
The content of PFAS should be less than 50 ppm (including polymer PFAS). If the total fluoride content exceeds 50 mg/kg, the manufacturer or importer must provide a certificate of compliance with the required fluoride content.
Packaging recycling requirements:
⑴ All the packaging for sale on the market should be recyclable.
⑵ If the packaging meets the following conditions, it will be regarded as recyclable:
a. Its design is aimed at material recycling, enabling the secondary recycled materials to be of sufficient quality compared to the original materials and capable of substituting for the latter.
When it is regarded as waste, it can be collected separately as per requirements and classified into specific waste streams without affecting the recyclability of other waste streams. It can also be recycled on a large scale in accordance with prescribed methods.
⑶ Manufacturers should assess the recyclability of packaging in accordance with relevant regulations. The recyclability of packaging should be indicated by the recyclability performance grades A, B or C as described in Table 3 of Appendix II of the regulations.
(4) Exemption of packaging categories: The Committee shall review the exemption of packaging categories by January 1, 2035.
a. Direct packaging and outer packaging of medicines;
. Contact-sensitive packaging for medical devices;
c. Contact-sensitive packaging for infant formula milk powder and subsequent formula milk powder, processed cereal foods and infant foods, as well as foods for special medical purposes;
d. Packaging for transporting dangerous goods;
e. Sales packaging made of lightweight wood, cork, textiles, rubber, ceramics, porcelain or wax.
The lowest recyclable component in plastic packaging
(1) Minimum recovery requirements for different time periods

⑵ The exemptions for packaging are as follows:
a. Direct packaging and outer packaging of medicines;
b. Contact-sensitive packaging for medical devices;
c. Biodegradable plastic packaging;
d. Packaging for transporting dangerous goods;
e. Contact-sensitive plastic packaging for food intended for infants and young children, food for special medical purposes, and beverages and food usually consumed by young children;
f. Packaging of veterinary drugs, their supplies, components and direct packaging components;
g. Plastic packaging in contact with food;
h. The plastic part which accounts for less than 5% of the total weight of the entire packaging.
⑶ The European Commission should adopt implementing regulations by December 31, 2026 to establish the calculation and verification methods for the percentage of recycled and regenerated materials in post-consumer plastic waste, as well as the technical document formats mentioned in Annex

VII;
By January 1, 2029 or 24 months from the effective date of the implementing act (whichever is later), the percentage of recycled materials in packaging shall comply with the rules stipulated in the implementing act.
Packaging minimization: By January 1, 2030, manufacturers or importers should ensure that the packaging designs released to the market take into account the shape and materials of the packaging, reducing its weight and volume to the minimum necessary to ensure its functionality.
Reusable packaging. Packaging that is placed on the market from February 11, 2025 and meets all of the following requirements will be regarded as reusable:
⑴ The purpose of its conception, design and market launch is to enable multiple reuses.
⑵ Its conception and design are aimed at achieving the maximum possible reuse under normal and predictable usage conditions.
⑶ It meets the applicable requirements regarding consumers' health, safety and hygiene.
⑷ It can be cleared or uninstalled without damaging the function for repeated use in the future.
(5) It can empty, unload, refill or reload the packaging products while maintaining their quality and safety, and ensuring compliance with applicable safety and hygiene requirements, including food safety requirements.
(6) It can be repaired in accordance with Part B of Annex VI and still maintain its ability to perform the intended functions.
⑺ Allow the labeling and provide information regarding the attributes of the product and the packaging itself, including any relevant explanations and information concerning the safety, proper usage, traceability and shelf life of the product.
⑻ It can be emptied, uninstalled, refilled or reloaded without posing any risk to the health and safety of the responsible personnel.
⑼ Meet the specific requirements of the designated recyclable packaging to ensure that it can be recycled when it becomes waste.
Packaging label requirements
⑴ Starting from August 12, 2028 or 24 months after the effective date of the law (whichever is later), the packaging to be put on the market shall bear a unified label, which shall contain information on the composition of its materials. The label shall be based on pictograms. QR codes or other types of standardized and open digital data carriers can also be placed on the packaging, containing information on the destination of each independent component of the packaging to facilitate consumers' classification.
⑵ Starting from February 12, 2029 or 30 months after the enactment of the law (whichever is later), reusable packaging that is put on the market shall be labeled to inform users that the packaging can be reused.
⑶ The committee should adopt and implement the bill by August 12, 2026, and formulate unified labeling requirements and format specifications.