Phase 1 General Application | 12-Aug-2026 | General application date across all EU member states:- Only compliant packaging can be placed on the EU market.
- Producers must carry out conformity assessment procedures, prepare technical documentation, and issue EU declarations of conformity (Article 15).
- Packaging minimisation requirements apply.
- Substance restrictions (Article 5) and compliance with limit values for substances of concern (e.g. lead, cadmium, mercury, chromium VI ≤100 mg/kg).
- PFAS restrictions (Article 5) for food-contact packaging take effect.
- Economic operators must comply with producer registration and Extended Producer Responsibility (EPR) obligations where applicable (Article 45).
| Ensure compliance documentation, PFAS restrictions, minimisation, and EPR obligations are in place. |
Phase 2 Labelling and Information Requirements | 12-Aug-2028 | Harmonised packaging labelling requirements take effect:- Packaging must be labelled with harmonised pictograms indicating material composition (sorting guidance). Where applicable, labelling of recycled content may also be required (Article 12).
| Update packaging artwork and labelling systems. |
Phase 3 Circular Economy Requirements | 01-Jan-2029 | Deposit Return Systems (DRS) (Article 50) must be established by Member States for:- Single-use plastic beverage bottles
- Metal beverage containers up to 3 litres
| Prepare for DRS participation and collection obligations. |
Phase 3 Circular Economy Requirements | 01-Jan-2030 | Recyclability Requirements (Article 6):- Packaging must achieve at least a specified recyclability performance level.
- Only packaging achieving recyclability grades A, B, or C may be placed on the market.
Recycled Content Targets (Article 7):- Mandatory minimum recycled-content requirements begin for various categories of plastic packaging. Higher targets will follow in 2040.
Packaging Minimisation (Article 24):- Empty space in grouped, transport, and e-commerce packaging generally limited to a maximum of 50%.
Reuse Targets (Article 29):Mandatory reuse and refill targets commence for specific sectors including: - Transport packaging.
- Beverage packaging.
- Certain commercial packaging formats.
| Meet recyclability, recycled-content, empty-space, and reuse-target requirements. |
Phase 4 Recycling Infrastructure | 01-Jan-2035 | Packaging must be shown to be “recyclable at scale”, meaning:- It is actually collected.
- It is sorted.
- It is recycled through established infrastructure at commercial scale across the EU.
| Demonstrate packaging is recyclable at scale. |
Phase 5 Tightened Recyclability Standards | 2038 | - Only packaging achieving the higher Recyclability Grades A or B may be placed on the market.
- Packaging meeting only Grade C standards will no longer be permitted.
| Achieve A or B recyclability grades only. |
Phase 6 Long Term Targets | 2040 | - Enhanced recycled-content targets apply to plastic packaging, increasing the requirements first introduced in 2030.
| Meet final recycled-content targets. |