Core requirements · Art. 5–29

Eight requirement families decide whether your packaging can be sold.

Everything else in the regulation is procedure. These eight are the substance — each one is an obligation you either meet, document, or cannot place on the market.

Grades · deadlines · legal basis · evidence

Instrument: Reg. (EU) 2025/40
Articles tracked: 5 – 29
In application: — days
Next binding date: 2028-08-12
Last reviewed: 2026-08-16

The register

Filter down to the ones that apply to you.

Most packaging is hit by three or four of these, not eight. Narrow by when the obligation bites, by material, or by the kind of packaging you ship.

When

Material

Format

8 of 8 requirement families

Art. 6 Recyclability+ Annex II Designed for recycling and graded A/B/C. Grade C is the floor from 2030, grade B from 2038, and from 2035 it must actually be recycled at scale. A / B / Cperformance grade 20302038 Art. 7 Recycled contentplastic parts only Minimum post-consumer recycled content per unit of plastic packaging, by material type and application. Averaged per plant per year, and it has to be verifiable. 30%PET, contact-sensitive 20302040 Art. 10 Minimisation+ Annex IV Weight, volume and layers reduced to the minimum necessary for function, argued criterion by criterion in a written justification you must be able to produce. Annex IVperformance criteria In force Art. 24 Empty space ratio+ Annex VII Grouped, transport and e-commerce packaging capped at 50% empty space. Void fill counts as empty space, so it changes box ranges and pick-and-pack, not just artwork. ≤ 50%of pack volume 2030 Art. 12 Labelling+ Annex IX Harmonised material-composition and separate-collection labels across all 27 markets, with a digital carrier for the extended information. A full artwork re-issue. 202812 August 2028 Art. 5 PFAS & substances of concernArt. 5(2) & 5(5) Food-contact packaging is effectively PFAS-free, and lead, cadmium, mercury and hexavalent chromium stay capped. The usual source is the coating, not the substrate. 25 ppbtargeted PFAS limit In force Art. 29 Reuse & refillArt. 27 & 29, Annex VI Binding sector targets for reusable systems, including transport packaging within the EU. Reusable means part of a functioning reuse system, not just a sturdier box. 40%transport packaging, 2030 20302040 Art. 11 · 38 Documentation & conformity+ Annex VIII Technical documentation and an EU declaration of conformity before the pack is placed on the market. Importers and distributors carry their own verification duties. DoCper packaging unit In force

Article 6 · how grading works

Recyclable is no longer a yes or no answer.

From 2030 recyclability is a graded performance, measured by the share of the pack that is actually recyclable by weight. The floor rises twice.

The scale

Design-for-recycling criteria are set per packaging category by delegated act. A pack is assessed against them and lands on a grade. Below grade C it cannot be placed on the market at all.

Grade A — 95% or more of the packaging is recyclable by weight.
Grade B — 80% or more. Becomes the market floor on 1 January 2038.
Grade C — 70% or more. The floor from 1 January 2030.
Below C — cannot be placed on the EU market.

The second test, from 2035

Designing for recycling stops being enough. From 1 January 2035 packaging must also be recycled at scale — meaning collection, sorting and recycling capacity genuinely exists for it in practice, not in principle. This is the provision that will decide the fate of most multilayer laminates.

What this means for a decision you make today

A laminate specified in 2026 will still be in market in 2030. If it cannot reach grade C under the coming criteria, the re-spec cost lands on you later, at a worse moment. This is why the delegated act due 1 January 2028 matters more than its date suggests.

A 95% or more recyclable by weight. The target state for mono-material formats. Best practice

B 80% or more recyclable by weight. 2038

C 70% or more recyclable by weight. The minimum to stay on the market. 2030

— Below 70% — cannot be placed on the EU market from 1 January 2030. Prohibited

Exploded comparison of uniform mono-material pouch layers and mixed multilayer laminate layers — Original technical illustration — layer structure of a mono-material pouch versus a multilayer laminate, with the recyclable fraction shaded.

Cross reference

Which requirement hits which material.

A first-pass map. It tells you where to look; the pack-level answer still depends on format, food contact and market.

Applies · conditional · not applicable, by material
Material	Art. 6 Recyclability	Art. 7 PCR	Art. 10 Minimisation	Art. 24 Empty space	Art. 12 Labelling	Art. 5 PFAS	Art. 29 Reuse
Plastic	●	●	●	◐ transport / e-com	●	◐ food contact	◐ by sector
Paper & board	●	— plastic only	●	●	●	● grease coatings	◐ by sector
Glass	●	—	●	◐ grouped packs	●	—	● beverages
Metal	●	—	●	◐ grouped packs	●	— unless coated	● beverages
Composite	● hardest case	◐ plastic parts	●	●	●	◐ barrier layers	◐ by sector

● Applies ◐ Conditional — Not applicable

Sourcing

Every figure on this page is citable.

Each requirement carries the article and annex it comes from, the date it takes effect separately from the date the regulation entered into force, and the date a human last checked it against the consolidated text.

How we source and review →

EUR-Lex32025R0040Consolidated

“All packaging shall be recyclable. Packaging shall be considered recyclable where it complies with the design for recycling criteria … and, from 1 January 2035, where it is recycled at scale.”

Regulation (EU) 2025/40 — Article 6(1), (4)

Legal basis: Art. 6 + Annex II
Effective date: 2030-01-01
Last reviewed: 2026-08-16
Revision: r4 — DfR act pending

Next — when it bitesTimeline Or start from your packPackaging

Next step

Which of the eight apply to your pack?

Enter material, format and market. You get the requirements that apply, the dates they apply from, and the evidence you will be asked for.

Check my packaging Testing routes