[Home](/)/[Resources](/resources)/EU Packaging Regulation EU packagingEPRsustainability # EU Packaging and Packaging Waste Regulation 2025: What Hardware Companies Must Know The EU's packaging rules are changing significantly. Regulation 2025/40 introduces mandatory recycled content requirements for new packaging, recyclability performance standards, packaging format restrictions, and strengthened extended producer responsibility. For hardware companies that distribute physical products in the EU, packaging is no longer just a marketing decision — it is a compliance specification. Copy Link[Share on WhatsApp](https://wa.me/?text=https%3A%2F%2Fkrono-labs.com%2Fguides%2Feu-packaging-regulation) [Check my EU packaging obligations](/platform/new) What changed ## From Directive to Regulation — the key shifts Regulation 2025/40 replaces the 1994 Packaging and Packaging Waste Directive (94/62/EC) with a directly applicable Regulation — no national transposition needed — and introduces substantially more prescriptive requirements. Recyclability requirements by 2030: all packaging placed on the EU market must be recyclable. Recycled content minimum percentages from 2030: mandatory minimums apply by packaging material type, ranging from 10% to 65% for plastic packaging depending on type and application. Packaging minimisation: maximum empty space ratios for transport packaging and restrictions on decorative packaging containing plastics. Extended producer responsibility: EPR systems must be harmonized across the EU by 2028, with uniform cost allocation methodologies. Eco-modulation fees — higher fees for packaging that is harder to recycle — will be applied across all EU member states. Mandatory sorting instruction symbols on consumer packaging using harmonized EU-wide labelling from 2028. Obligations ## What hardware companies selling packaged products in the EU must do EPR registration: if you are the producer of packaging — the brand owner or first importer placing packaged products on the EU market — you must register with the EPR system in each EU member state where you sell. Registration is typically through a Producer Responsibility Organisation (PRO). EPR fees are calculated based on the weight and type of packaging placed on the market. Packaging design: from 2030, all new packaging must meet the Regulation's recyclability and recycled content requirements. Decisions being made now about packaging format, material selection, and construction should target the 2030 requirements. Data collection for EPR reporting requires annual declarations of packaging placed on the market by material type and weight — each component (cardboard outer, plastic insert, foam padding, plastic film) must be tracked and reported separately. Practical steps ## How to prepare for the new packaging rules Step 1: Audit current packaging. Map every component of your packaging by material type and weight. This audit is the basis for EPR reporting and reveals which elements will face recyclability challenges. Step 2: Register for EPR in your main EU markets now if you have not already. EPR registration is already required under the existing Directive in most member states — operating without EPR registration is already a compliance violation in Germany, France, and other major EU markets. Step 3: Review packaging design against recyclability targets. EPS (expanded polystyrene) foam inserts, multi-material laminate films, and dark-coloured plastic components are the most common recyclability problem areas for electronics packaging. Alternative materials — moulded pulp inserts, corrugated cardboard, mono-material plastics — are available substitutes. Step 4: Establish recycled content tracking in your packaging supply chain by collecting supplier declarations and verification documentation now rather than scrambling before 2030. ## Learn this properly, not just for one product In-depth courses and books that teach the process — not a one-off answer you'll need to look up again next time. [Start the course — $149](/courses/38-eu-ppwr-electronics-hardware-sellers)See your free roadmap [Prefer to read? Get the book — $24.99](/books/38-eu-ppwr-electronics-hardware-sellers) ## Frequently asked questions ### Is the EU Packaging Regulation already in force? Regulation 2025/40 was published in early 2025 and is being phased in. Some provisions apply immediately (substance restrictions, EPR registration obligations, reporting requirements). The recyclability and recycled content targets phase in from 2030. The harmonised packaging symbols apply from 2028. EPR registration is already required in many EU member states under the preceding Directive. ### Does the EU Packaging Regulation apply to product packaging or only to packaging companies? The Regulation applies to producers of packaged products — the brand owner or first importer who places packaged products on the EU market. Hardware companies are producers under this definition and are responsible for EPR registration, packaging design compliance, and recycled content requirements. Packaging companies that supply packaging materials have separate obligations for substance restrictions and recyclability certification. ### What is eco-modulation in EPR fees? Eco-modulation is a fee structure where EPR contributions are adjusted based on the environmental performance of the packaging. Packaging that is harder to recycle (dark-coloured plastics, multi-layer laminates) pays higher EPR fees. Packaging with higher recycled content pays lower fees. The Regulation requires EU-wide harmonised eco-modulation methodologies from 2028. ### Does the packaging Regulation apply to transit packaging? Yes, to a degree. The Regulation covers all packaging placed on the EU market — consumer packaging, commercial packaging, and transport/industrial packaging. Different requirements apply to each category, with consumer packaging facing the strictest format and labelling requirements. Transit packaging has lighter requirements but must still meet substance restrictions and EPR registration obligations. 🇪🇺 CE Marking roadmap for plastic packaging Every standard, document, and test that applies — free, no account required. See your free roadmap[ Want an expert to take plastic packaging through 🇪🇺 CE Marking compliance for you? One consultant from Krono's compliance team takes your product from requirements to legal sale, with a fixed quote before any work starts. See compliance services](/services) Learn this properly In-depth course that teaches the full process, not just this one answer. [Start the course — $149](/courses/38-eu-ppwr-electronics-hardware-sellers)[Prefer to read? Get the book — $24.99](/books/38-eu-ppwr-electronics-hardware-sellers) Related guides * [EU Economic Operators ExplainedThe EU product safety framework assigns distinct compliance obligations to each economic operator in the supply chain.](/guides/eu-economic-operators-explained) * [EU Supply Chain Due Diligence (CSDDD)The EU CSDDD (Directive 2024/1760) requires large companies to identify, prevent, and address adverse human rights and environm…](/guides/eu-supply-chain-due-diligence) * [EU Digital Product PassportThe EU Digital Product Passport is a core element of the Ecodesign for Sustainable Products Regulation (ESPR).](/guides/eu-digital-product-passport) * [EU CN Codes for ElectronicsThe EU Combined Nomenclature (CN) is the 8-digit customs classification system for all EU imports.](/guides/eu-cn-codes-electronics) Educational resource only. EPR obligations and registration procedures vary by EU member state. Verify current requirements with qualified compliance professionals and local PROs in each target market.