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What starts when

What applies now, and what comes later

Most of what is written about these rules makes it sound as though everything arrived at once. It did not.

Everything here was last read from its source on .

Now

Already applies

A duty is only later than the day the rules started where its own wording says so. These say nothing of the kind, so they apply today.

Checking packaging against the design rules

Before the declaration can be written, the packaging has to be checked against the design rules. The rules set out the procedure to follow for that check. Somebody else can carry out the check, such as a laboratory, but the business named as manufacturer still carries the responsibility.

Source: Regulation (EU) 2025/40, Art. 38 — read from this source on

The declaration of conformity, and who has to write one

Anyone counting as the manufacturer of packaging writes a short document saying the packaging meets the design rules. It is called an EU declaration of conformity. The rules fix what goes in it and set out a model to follow. It has to be kept up to date, and written in a language the country where the packaging is sold asks for. Signing it means taking responsibility for what it says.

Source: Regulation (EU) 2025/40, Art. 39 — read from this source on

What happens if paperwork is missing or wrong

For paperwork problems, the first step is being asked to put it right. That covers a declaration that was never written, one written incorrectly, and technical records that are missing, incomplete or wrong. Only if the problem carries on does a country move to stopping the packaging being sold, or having it recalled. A different set of problems, about the packaging itself rather than the paperwork, goes straight to national penalties instead.

Source: Regulation (EU) 2025/40, Art. 62 — read from this source on

Selling to another EU country and needing a representative there

A business that sends packaged goods straight to customers in another EU country has to appoint someone based in that country to handle its packaging duties there. The rules call this person an authorised representative for extended producer responsibility. It has to be done in writing, and separately for each country. For businesses based outside the EU the picture is different: each country decides for itself whether to require one.

Source: Regulation (EU) 2025/40, Art. 45(3) — read from this source on

Double walls, false bottoms and packaging that looks bigger than it is

Packaging built only to look bigger than it needs to be cannot be put on the market. The rules name double walls, false bottoms and unnecessary layers, and also set performance criteria packaging has to meet. This one has no later start date of its own, so it started with the rest of the rules on 12 August 2026. Two narrow exceptions exist. One covers a design or shape trademark protected before 11 February 2025, where meeting the rule would spoil what makes it distinctive. The other covers products with a protected geographical indication or under an EU quality scheme.

Source: Regulation (EU) 2025/40, Art. 10(2), read with Art. 71 — read from this source on

What counts as a micro-enterprise

A micro-enterprise is a business with fewer than 10 people whose yearly turnover or balance sheet total stays at or below 2 million euro. The catch is that these are not always just one company's own numbers. If another company owns a quarter or more of the business, a share of that company's staff and money gets counted in too. If one company controls the other outright, all of it counts. So even a one-person business can fall outside the definition.

Source: Commission Recommendation 2003/361/EC, Annex, Art. 2(3), Art. 3 and Art. 6 — read from this source on

The exception for very small businesses

There is one way out of counting as the manufacturer of packaging carrying a business's own brand. Two things both have to be true: the business is a micro-enterprise, which the rules define by staff numbers and money, and the company supplying the packaging is based in the same country. When both hold, the supplier counts as the manufacturer instead.

Source: Regulation (EU) 2025/40, Art. 3(1), point (13)(b) — read from this source on

Packaging that carries a business's own name or logo

If a business has packaging made carrying its own name or logo, the rules treat that business as the packaging's manufacturer. That is the word the rules use, and it applies even when someone else's brand also appears on the box. Printed tape, a branded mailer or a bag with a logo are enough. Buying plain unbranded boxes is not.

Source: Regulation (EU) 2025/40, Art. 3(1), point (13) — read from this source on

When a business counts as a producer, and in which country

Producer is the word the rules use for whoever first puts packaging onto a country's market. It is worked out country by country, so one business can be a producer in several countries at once. There are five ways to become one. Two cover selling packaged goods at home. Two cover sending packaged goods straight to customers in another EU country. The fifth catches a business that unpacks goods without being the one who uses them, unless somebody earlier in the chain already counts as the producer.

Source: Regulation (EU) 2025/40, Art. 3(1), point (15) — read from this source on

Letting someone else hold the paperwork

A business counting as the manufacturer can appoint someone in writing to deal with authorities on its behalf. The rules call this an authorised representative. That person keeps the declaration and the supporting paperwork available for authorities and answers their questions. They produce documents within 10 days when asked, and can walk away if the business ignores its duties. Records are kept for 5 years for single-use packaging and 10 years for reusable packaging. Writing the technical paperwork is not part of the job.

Source: Regulation (EU) 2025/40, Art. 17 — read from this source on

Getting packaging details from a supplier

Most small businesses cannot test what their boxes are made of, and they do not have to. Whoever sells them the packaging has to hand over the information and paperwork needed to show it meets the rules, in a language they can follow, on paper or by email. Asking for it is not a favour. It is something the supplier owes.

Source: Regulation (EU) 2025/40, Art. 16(1) — read from this source on

2030

Starts in 2030

A date written into the rules, depending on nothing else happening first.

Keeping packaging to the minimum weight and volume

By 1 January 2030, packaging put on the market has to be designed so its weight and volume are cut to the minimum needed for it to still do its job. The shape and the material both get taken into account. This is a flat date. It does not wait on anything the European Commission has yet to decide.

From

Source: Regulation (EU) 2025/40, Art. 10(1) — read from this source on

No date

Cannot start yet

Each of these begins on a date or a fixed period after the European Commission adopts something, whichever falls later. Because that decision has not been made, no start date can be given — and a late decision moves the duty back rather than shortening the time to get ready.

The limit on empty space in boxes

Businesses that fill grouped, transport or e-commerce packaging will have to keep empty space to no more than half the box. This starts on 1 January 2030 or three years after the European Commission's method for measuring empty space takes effect, whichever comes later. The rules ask the Commission to adopt that method by 12 February 2028.

Waiting on: The European Commission's implementing act on measuring empty space

Source: Regulation (EU) 2025/40, Art. 24(1) and Art. 24(2) — read from this source on

Recycled content in plastic packaging

Plastic parts of packaging will have to contain a minimum share of recycled material recovered from plastic waste, worked out as an average per plant per year. The share differs by packaging type. This starts on 1 January 2030 or three years after the European Commission's method for calculating it takes effect, whichever comes later. That method does not exist yet, so the start date cannot be fixed.

Waiting on: The European Commission's implementing act on calculating recycled content

Source: Regulation (EU) 2025/40, Art. 7(1) — read from this source on

The single EU-wide reporting format that does not exist yet

The rules ask the European Commission to set one common format for registering and reporting packaging, and gave it a deadline of 12 February 2026. That has not happened. Once it does, countries get 18 months to build registers that match it. Until then, registering and reporting works the way each country already does it, and there is no common EU format to prepare for.

Waiting on: The European Commission's implementing act on registration and reporting format

Source: Regulation (EU) 2025/40, Art. 44(1) and Art. 44(14) — read from this source on

What the European Commission still has to decide

Several of the rules above cannot start until the Commission works out the detail — how to measure something, or what a label has to look like. It has published a date it aims to do each one by.

These are the Commission's own targets, not deadlines that bind anybody. Some have already gone past without the decision being made. That is worth knowing rather than worrying about: a late decision pushes the duty further away, it does not shorten the time to get ready.