EU New Packaging Regulation (EU) 2025/40

On January 22, 2025, the European Commission approved the new EU Packaging and Packaging Waste Regulation (PPWR) 2025/40, which applies to all packaging (regardless of material) and all packaging waste (regardless of purpose or flow). PPWR has revised the regulations (EU 2019/1020 and (EU) 2019/904) and will officially abolish and fully replace the current Directive 94/62/EC on August 12, 2026. This regulation covers the supervision of the entire lifecycle of packaging, from design, manufacturing, sales to disposal and recycling, comprehensively promoting the recycling and resource efficiency improvement of packaging.

The core content of this regulation is as follows:

Reduce packaging waste

Explicitly require the reduction of overall waste generation through lighter and smaller packaging designs, as well as the promotion of reusable designs.

Recyclability

All packaging placed on the market must be recyclable and meet the EU's recyclability performance levels (A/B/C) starting from 2030, further tightened to only A or B levels starting from 2038. Excluding some special purpose packaging (such as pharmaceuticals, baby food) and compostable packaging.

Minimum recycling rate in plastic packaging

Packaging type January 1, 2030 January 1, 2040

Contact sensitive packaging with PET as the main component (excluding disposable plastic beverage bottles) 30% 50%

Contact sensitive packaging made of non PET plastic materials (excluding disposable plastic beverage bottles) 10% 25%

Disposable plastic beverage bottles 30% 65%

Other plastic packaging 35% 65%

Requirements for packaging labels/waste container labels

Starting from 2028, all packaging must be labeled with a unified graphic label indicating the material composition, facilitating consumer classification, and clearly indicating information such as compostability, recyclability, and reusability; Relevant information can be provided through open digital carriers such as QR codes.

Starting from 2028, member states must ensure that containers used for collecting packaging waste are labeled uniformly, indicating the type of packaging material that should be put into the container for classification and recycling.

Limit harmful substances (heavy metals and PFAS)

Packaging materials: The total content of lead, cadmium, mercury, and hexavalent chromium shall not exceed 100 mg/kg.

Food packaging materials: The detection limit for a single PFAS substance is less than 25 ppb (excluding quantification of polymer PFAS)

Food packaging materials: After precursor degradation, the total amount of PFAS is less than 250 ppb (excluding quantification of polymer PFAS)

Food packaging materials: PFAS (including polymer PFAS)<50 ppm (if the total fluoride content exceeds 50 mg/kg, proof of fluoride content should be provided)

The new regulations not only bring challenges, but also opportunities to seize the green market. It is recommended that relevant packaging manufacturers lay out early and start from three aspects: design optimization, material selection, and labeling standards, to create a packaging system that meets EU requirements, in order to take the initiative in the future green trade chain.

If you have any questions, please contact us. We will be dedicated to providing you with the latest regulatory information and high-quality testing and certification services.

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Shenzhen Element Testing Co., Ltd. (referred to as Element) focuses on providing testing and compliance services for electronic atomizer enterprises.

The Element laboratory is equipped with dozens of advanced detection instruments and equipment, such as imported simulated smoking machines (Vaping Machines), liquid chromatography triple series quadrupole liquid chromatography-mass spectrometry (LC-MS-MS), inductively coupled plasma mass spectrometry (ICP-MS), gas chromatography-mass spectrometry (GC-MS), inductively coupled plasma emission spectrometer (ICP-OES), high-performance liquid chromatography (HPLC-DAD), gas chromatography (GC-FID/ECD/TCD), ion chromatography (IC), X-ray fluorescence spectroscopy (XRF), electronic cigarette life testing machine, pressure relief safety tester, pressure relief safety tester, glow wire tester, needle flame tester, IPX3, IPX4 testing Box, salt spray testing box, constant temperature and humidity box, mechanical testing system, battery pack drop stacking testing machine, electrostatic discharge (ESD) tester, etc.

The staff of Element Laboratory have a bachelor's degree or above and have worked in the field of testing and compliance services for many years. Among them, the engineer of the electronic atomizer project is one of the first senior experts in China engaged in electronic atomizer testing and compliance services.

Element adheres to the research of laws, regulations, and testing standards, continuously delivers the latest legal and regulatory information to customers, completes the method validation of new testing standards in the first time, and applies them to the testing of related products.