EU Regulation 2025/40 on packaging corrected: what manufacturers and distributors must review

Key data

If your company manufactures, uses or manages packaging in the EU, the regulatory framework governing your activity has just been updated. Regulation (EU) 2025/40, approved on 19 December 2024 and published on 22 January 2025, has received an official correction (errata) published on 4 August 2026 that corrects material or drafting errors detected after its initial publication.

This regulation is not a minor standard: it completely repeals Directive 94/62/EC —the European reference framework on packaging for more than 30 years— and amends both Regulation (EU) 2019/1020 and Directive (EU) 2019/904 on single-use plastics. An errata in a text of this magnitude can affect specific obligations, deadlines or technical definitions that you were already applying.

What does this regulation establish?

Regulation (EU) 2025/40 is the new European pillar on packaging and packaging waste. It replaces Directive 94/62/EC, which has been in force since 1994, and raises requirements in three major areas:

• Reuse: Establishes requirements for certain packaging to be designed and marketed with reuse systems.
• Recyclability: Sets design criteria so that packaging is effectively recyclable.
• Reduction: Introduces obligations to minimize the volume and weight of packaging.

The adaptation deadlines are staggered, which means that not all obligations come into force at the same time. The correction published on 4 August 2026 corrects material or drafting errors detected in the original text. Although the exact nature of each correction is not detailed in the available information, in regulations of this complexity errata can affect definitions, cross-references between articles, specific deadlines or technical requirements.

As for the standards it modifies or repeals, the impact is as follows:

Economic and operational impact

Regulation (EU) 2025/40 is not a standard with marginal impact. The transition from Directive 94/62/EC involves moving from a framework of harmonized minimums —where each Member State could go further or less far— to a regulation of direct and uniform application throughout the EU. This eliminates the possibility of taking advantage of more lenient national frameworks.

The main cost vectors for companies are:

• Packaging redesign: Adaptation to new recyclability and reuse criteria, with possible investments in R&D, molds and materials.
• Collection and return systems: Reuse obligations may require additional logistics infrastructure.
• Compliance audit: Review your entire portfolio of packaged products against the new requirements, especially following the correction published.
• Staggered deadlines: Financial planning must be aligned with the different time horizons established by the regulation for each type of obligation.

The August 2026 correction adds an immediate operational cost: any company that has developed adaptation plans, trained its team or updated internal procedures based on the original text must verify whether any of the corrections affect decisions already made.

Who does it affect?

• Packaging manufacturers: Companies that produce packaging from any material (plastic, glass, metal, cardboard, wood) intended for the European market.
• Packagers: Companies that use packaging to market their products, regardless of sector (food, cosmetics, pharmaceuticals, industry, etc.).
• Distributors: Companies that place packaged products on the market, including importers from third countries.
• Packaging waste managers: Companies engaged in collection, sorting, recycling and recovery of packaging waste.
• Integrated waste management systems (IWMS): Entities responsible for meeting recycling targets on behalf of producers.
• Compliance and sustainability departments: Responsible for ensuring regulatory compliance in companies in the above sectors.

Practical example

A food company that packages products in plastic trays had reviewed its packaging catalog in February 2025 against the original text of Regulation (EU) 2025/40, identifying which references met the new recyclability criteria and which required redesign. It had developed a transition plan with specific dates based on the staggered deadlines of the regulation.

With the publication of the correction on 4 August 2026, this company must now compare the corrected text with the original to verify whether any of the errata corrected affects the technical definitions of recyclability it used as a basis, the adaptation deadlines it set in its roadmap, or the cross-references with Directive (EU) 2019/904 that apply to its single-use plastic packaging. If any correction modifies a deadline or technical definition, the transition plan will need to be updated before continuing to execute it.

What should companies do now?

1. Download and compare the corrected text: Access the correction published in the EU Official Journal and compare it with the original text of 22 January 2025 to identify exactly what has changed.
2. Review existing adaptation plans: Verify whether any correction affects deadlines, technical definitions or specific requirements that were already incorporated in the company's compliance roadmap.
3. Update internal documentation: Replace any reference to the original text with the corrected text in procedures, packaging design policies and contracts with suppliers.
4. Inform product and procurement teams: Ensure that those responsible for packaging design and packaging material buyers work with the current and corrected regulatory version.
5. Consult with a specialized advisor: If the correction affects obligations already in execution or committed investments, evaluate with an expert in packaging regulations the specific impact and available options.

Official source

Consult complete regulation in official source

Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202690654