Packaging and Packaging Waste Regulation: core obligations apply (minimisation, PFAS ban in food packaging, conformity documentation, EPR registration)

What changes

Regulation (EU) 2025/40 applies directly in all Member States. Packaging must be minimised (e-commerce parcels max 40% empty space), food-contact packaging with PFAS above limits is banned, every packaging type needs a conformity assessment and technical documentation, and producers must register for extended producer responsibility in each country where they place packaged goods. Further deadlines follow (harmonised labels 2028, recycled-content minimums 2030).

Who is affected

Anyone who places packaged products on the EU market: manufacturers, importers, distributors, online sellers and fulfilment providers, regardless of size.

Sizes: micro, small, medium, large · Sectors: E-commerce, Retail, Manufacturing, Hospitality / tourism, Agriculture / food · Applies if: We sell online; We sell to consumers (B2C); We import goods into the EU; We make connected hardware / devices

What to do

Inventory your packaging by type and material and check empty-space ratios, PFAS content and heavy-metal limits. Create a technical file and declaration of conformity per packaging type. Register with the producer-responsibility scheme in every country you ship to and appoint an authorised representative where required for distance sales.

Penalty

Set nationally; typically fines and market withdrawal

Sources

• European Commission – Packaging waste (environment.ec.europa.eu)
• Gleiss Lutz – New EU Packaging Regulation: key requirements from August 2026 (www.gleisslutz.com)

Last verified 7 September 2026. Informational only, not legal advice.

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