The new European rules for packaging

If you use packaging to pack, ship or serve products, the new European regulation may apply to you

From 12 August 2026, Regulation (EU) 2025/40 - the so-called PPWR (Packaging and Packaging Waste Regulation) - takes effect, rewriting the European rules on packaging.

The starting point is that the Regulation does not concern only those who make packaging. It can also affect anyone placing packaged products on the market: online sellers who ship goods, takeaway and delivery food businesses, retail, artisan food producers, manufacturers exporting into Europe. If a product is sold or shipped inside a box, a tray or a bag, it is worth checking which obligations apply.

Among the changes, certain capsules, pods and sachets for tea, coffee and other beverages now fall expressly within the definition of packaging. For the businesses concerned, this reclassification may have consequences for environmental, contribution and labelling obligations.

It should be noted that the obligations do not all take effect at once. The Regulation sets out a phased path: some rules apply immediately, others will come into force between 2027 and 2030, while several aspects still await the Commission's implementing acts.

In practice, it is worth distinguishing two aspects from the outset: the environmental and contribution obligations tied to placing packaging on the market, and the technical compliance obligations that may fall on those who use packaging customised with their own brand.

The change that affects the most businesses: EPR registration

The PPWR requires anyone placing packaging on the market to register in the producer register for the purposes of extended producer responsibility. What is new is that registration is no longer cumulative: it must be completed in each Member State where the packaging is first made available.

In concrete terms, for example: a company selling in Italy, Germany, France and Spain will handle four separate registrations, with annual contributions and reporting under each country's rules. The same applies to e-commerce businesses shipping directly to consumers abroad. In Italy, CONAI membership still applies, but it covers only the domestic market.

The sensitive point: if your brand is on it, the “manufacturer” is you

This is the most misunderstood aspect, because the Regulation (Art. 3(1)(13)) also treats as a manufacturer anyone who has packaging designed or produced under their own name or brand, even without physically making it.

The range of cases is broad: e-commerce boxes printed with your logo, customised mailers, retailers' private-label products, industrial shippers bearing the company name, a bar's or restaurant's cups and trays, the presentation boxes of a winery or an artisan workshop. In these cases, responsibility for compliance may not remain with the supplier and should be checked carefully, taking account of the actual role played in the supply chain.

From 12 August, anyone qualifying as a manufacturer must: carry out the conformity assessment; keep the technical documentation (Annex VII); draw up the EU declaration of conformity (Annex VIII); state their identifying details and a unique reference to the packaging, such as type, batch or serial number, including via an accompanying document; and take corrective measures if something is not in order. The documentation and the declaration must be kept for five years for single-use packaging and ten for reusable packaging.

There is, however, an exception: if the party customising the packaging is a micro-enterprise - fewer than 10 employees and annual turnover or balance-sheet total not exceeding EUR 2 million - and the supplier is established in the European Union, the status of manufacturer falls on the supplier (Art. 15(12)). This is not automatic, so it must be verified that the requirements are genuinely met and that the supplier provides the documentation.

What the declaration must certify, as things stand

Not everything, which makes the task simpler. From 12 August the declaration covers three points: the limits on heavy metals for all packaging; the ban on PFAS above very low thresholds in food-contact packaging, with particular attention to paper and board given a grease- and moisture-barrier treatment; and confirmation that packaging designed for reuse genuinely is reusable. Recyclability, recycled content, minimisation and labelling will enter the declaration later, as their respective requirements become applicable.

Stock in the warehouse does not have to be destroyed

One useful clarification concerns existing stock. Packaging produced before 12 August and not yet placed on the market may continue to be used, without destruction or relabelling, provided the packaging identification and the manufacturer's details can be found in an accompanying document. Packaging already placed on the market stays in circulation.

The exception is the chapter on substances, where no leeway is allowed: and since, for retail packaging, placing on the market coincides with filling rather than with purchase, trays bought in June and still empty in September need to be checked.

The timeline

When	What happens
12 Aug 2026	EPR registration, declaration of conformity, PFAS and heavy-metal limits.
2027 – 2029	Harmonised European label with sorting pictograms from 12 August 2028; national labels superseded, and deposit-return schemes for plastic bottles and cans from 1 January 2029.
1 Jan 2030	Minimum recycled content in plastic, reduced packaging weight and volume, a 50% cap on empty space in shipments, a ban on the single-use formats in Annex V (including trays for fruit and vegetables under 1.5 kg and single portions served at the table), and reuse and refill obligations for takeaway and beverages.

On penalties, the Italian framework is still being defined: the enabling mandate to the Government expires on 9 December 2026. A national decree is, however, on its way, introducing a requirement of certified compostability for fresh fruit and vegetables, food service and catering, single portions and hospitality, effective from 2030.

First checks we recommend

• Take stock of the packaging you use: material, supplier, presence of your brand, destination markets.

• Establish your role for each type (manufacturer, importer, distributor) and check whether you fall under the micro-enterprise exception.

• Verify your EPR registrations in every EU country where you sell, not only in Italy.

• Write to your suppliers and request technical data sheets and attestations, particularly for food contact.