The top level legislation responsible for the complex rules dealt with on this website.
[1] Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC (Text with EEA relevance)
https://eur-lex.europa.eu/eli/reg/2025/40/oj/eng
Very reasonable - to ensure that fragmented or unclear rules on packaging do not cause inefficiency in the internal market.
But the EU also aims for 'a low-carbon circular economy'. It already has a 'Circular Economy Action Plan' (CEAP). This means that there are many goals already set in areas such as recycling and environmental gains etc. This results in final requirements that are far more ambitious than simple harmonisation.
There are many definitions but the following shows the wide coverage: 'sales packaging corresponds to primary packaging, grouped packaging to secondary packaging and transport packaging to tertiary packaging'.
The scope of the legislation is very wide, for example: 'labels hung directly on or affixed to a product, including sticky labels affixed to fruits and vegetables, should be considered to be packaging'.
The legislation is very keen on 'packaging recyclability based on a design for recycling methodology'. It notes that some member states already have such an approach and seeks merely to harmonise these.
A great deal of discussion is had on the complexities of recycling plastic. It is assumed that the original document will be studied by those making plastic packaging.
These are areas that will, in time, require action by businesses planning to sell into and across the European market. Note though that the cliff edge for many requirements is around January 1 2030.
'Obligation related to excessive packaging' This is covered in Article 24. It is important to note that implementation is by 2030 rather than being immediate. It states things like: 'grouped packaging, transport packaging or e-commerce packaging shall ensure that the maximum empty space ratio, expressed as a percentage, is 50%'. The 'methodology for the calculation of the empty space ratio' is itself due in 2028.
'Packaging minimisation' This is covered in Article 10. Again it has a deferred date as illustrated by its opening: 'By 1 January 2030, the manufacturer or importer shall ensure that the packaging placed on the market is designed so that its weight and volume is reduced to the minimum necessary to ensure its functionality'. However it would certainly be wise, in the shorter term, to eliminate 'deceptive space', which is that used to imply larger volume than actually supplied.
'Recyclable packaging' This is covered in Article 6 and deals with materials used and their ease of entry to the recycling processes. Again there are deferred dates to meet the recycling requirements from 2030 or even 2035.
'Substances of concern' This covers areas such as use of heavy metals, PFAs etc. Clearly important but not of specific concern to the average business exporter.
This is potentially the most costly and bureaucratic area for businesses exporting to the European market
'Registers of producers' The regulation at Article 44 says that each member state should 'monitor compliance of producers'. So if your product is supplied with packaging you have forms to fill in in each destination country.
A good place to find links to these is the European National Registers for Packaging network (EUNR) https://www.eunr.org/.
For example this leads to the relevant Belgium site:
the Interregional Commission for EPR (EPRiBEL) https://www.ivcie.be/en/. This in turn leads to the online form where you can declare your packaging (available in various languages). Many countries are believed to require a local representative. More on this when information becomes available.