Packaging: the countdown to Regulation (EU) 2025/40 has already started

One of the least intuitive parts of the regulation is working out what role each company plays. It defines several roles with different obligations — manufacturer, importer, distributor, producer under extended responsibility, packer — and it is not unusual for a single company to fit into more than one at once. A distributor selling own-brand packaging, for instance, takes on the same legal obligations as a manufacturer.

From 12 August 2026 several requirements become enforceable: a ban on PFAS in food-contact packaging, limits on certain heavy metals, a cap on empty space inside packaging (no more than 40%), restrictions on certain single-use formats, registration with extended producer responsibility schemes and — perhaps the most decisive — no packaging may be placed on the market without its EU Declaration of Conformity.

And this is only the beginning. February 2027 brings reuse and refill obligations for hospitality; 2028 brings harmonised labelling and the digital product passport; and through to 2040 ever more demanding recyclability and recycled-content targets will keep being added.

If you manufacture, import, pack or distribute packaged products and you still haven’t identified your role, prepared your Declaration of Conformity or set a clear roadmap, it’s worth sorting out sooner rather than later. At GAIA we run a specific PPWR diagnosis to make clear what’s missing and where to start.