Edited by Paola Furiosi, Francesca Caliri, and Cecilia Costanzi
On February 11, 2025, Regulation (EU) 2025/40 on packaging and packaging waste -better known by the acronym “PPWR” – entered into force. This regulation will replace Directive 94/62/EC, introducing a single, binding, and directly applicable framework in all Member States.
Its impact is expected to be significant: it is not merely a legislative update, but a radical change for the European industry, which is called upon to significantly reduce the production of packaging waste by complying with reuse and recycling obligations, ensuring packaging sustainability, and harmonizing labeling requirements.
The new provisions will gradually apply after the 18-month transition period provided ex lege, that is, starting from August 12, 2026, with the goal of drastically reducing the volume and environmental impact of packaging by 2040.
A New Approach: Rethinking Packaging Design
The Regulation overturns the traditional perspective on packaging: whereas, ab origine, the focus was on downstream management (i.e., disposal) of packaging, today the focus shifts upstream, to the design phase.
Starting in 2030, all packaging placed on the European market must be reusable, recyclable, or compostable, according to harmonized technical criteria. In this regard, design aimed at recycling packaging, known as “Design4Recycling,” requires particular attention both to the reusability and recyclability of the materials used.
Reusability and recyclability will be verified through specific performance indicators, which will not only determine the possibility of marketing the products but will also have an economic impact on the production chain. Less sustainable packaging will, in fact, be subject to higher eco-modulated contributions, while the disposal of higher-quality and more easily recyclable packaging will result in cost reductions: the aim is, therefore, to penalize less virtuous business choices.
From Combating Waste to Mandatory Labeling Clarity
Another key point of the new regime is the fight against so-called “overpackaging”, whereby the weight and volume of packaging must be reduced to the minimum necessary to ensure the functionality of the product.
These new provisions will affect multiple and various industries (including textiles, food, cosmetics, pharmaceuticals, logistics) and will imply – inter alia – the inadmissibility of adding aesthetic elements to packaging, such as double walls or raised bottoms, designed to artificially increase the perceived volume.
Furthermore, regarding environmental communication, the Regulation aligns with the European Union’s strategy to contrast greenwashing, severely limiting environmental claims related to packaging: as a result, companies may only claim “green” performance if it exceeds the minimum standards set by the Regulation itself and is supported by a compliant technical statement.
Extended Producer Responsibility
The PPWR also systematically strengthens the extended producer responsibility (or “EPR”), a principle already known at the European level, which assigns producers the financial and organizational responsibility for managing the packaging placed on the market, from the design phase to the collection, recycling, and disposal of packaging waste.
Specifically, the new provisions require that anyone placing packaging on the European market (with obligations also extended to importers and distributors) must register with a national register, providing detailed information on quantities and materials used, and that producers may fulfill their obligations either individually or by joining collective systems, such as consortia or recognized management organizations subject to oversight by the competent authorities.
The objective is clear: to prevent and reduce the production of packaging waste, promote innovative and sustainable solutions, and ensure that the costs of waste management are borne by those who place packaging on the market, in line with the “polluter pays principle”.
Legal Compliance: From Duty to Strategy
The regulatory framework outlined here does not merely establish new obligations but prompts companies to rethink packaging as a central element of their business and reputational strategy.
From an operational perspective, companies will be required to implement information systems to track the composition of packaging, monitor the percentages of recycled material, and manage the documentation required to ensure compliance, which must be complete, accessible, and verifiable for at least 5 years (up to 10 years in the case of reusable packaging).
Contracts with suppliers, carriers, and logistics partners will also need to be reviewed to clearly allocate risks and responsibilities. In addition, it will be advisable to plan internal training sessions to update staff on new design, labeling, and document management procedures.
In this context, the challenge also represents an opportunity. Anticipating requirements, innovating, differentiating packaging, from a simple container, becomes the first business card of corporate sustainability, enabling companies to position themselves as leaders in the new European circular economy.
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