New EU packaging: applicable from August 2026

    The Regulation (EU) 2025/40, on Packaging and Packaging Waste (PPWR), was published in the Official Journal of the European Union last January. This regulation is legally binding for all Member States (MS).

    The key actions and timelines to consider are:

        • 11/Feb/2025: entry into force.

        • 12/Aug/2026: mandatory application.

        • Jan/2028: Design for Recycling criteria and performance grades to be published.

        • 2030: mandatory for producers and retailers, all packaging must meet minimum recyclability standards.

        • 2035: full-scale recyclability required at the EU level.

        • Functional packaging to closely match product dimensions, with unnecessary packaging and void space to be minimised or removed.

        • Packaging to include a digital passport detailing its material composition, recyclability, and end-of-life management.

        • Standardised labelling to be introduced, with clear labels that indicate disposal methods and material composition, to ensure consistent information for consumers and industry.

    Major hurdles already identified by manufacturers:

        • New stability testing will be required when changing packaging materials.

        • Significant costs associated with new materials, machinery upgrades, and validation processes.

        • For plastic jars and lids:

                – PPWR-compliant materials are available but tend to be more expensive

                – Commercial viability of colored jars.

        • For blisters:

                – Limited compliant solutions are available (mono-material blisters to be an option?).

                – New machinery or adaptations will be needed for recyclable materials.

This is a developing narrative; we will update it as new information emerges.