Packaging rules
The packaging regulation has applied in every member state since 12 August 2026. As reported, it asks for a declaration of conformity per packaging type, an identification element on the pack and limits on substances.
As of 15 October 2026. This guide is general information, not legal advice.
Every parcel you ship is also packaging, and packaging now has its own regulation. The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, entered into force on 11 February 2025 and has applied directly since 12 August 2026. Directly means there was no national law to wait for and no transition: it applies in every member state in the same words, from the same day.
Current duties
In the order a packing team meets them: first, a signed declaration of conformity for each packaging type you use, backed by technical documentation that shows the packaging meets the regulation's requirements, which sit in Articles 5 to 12. A mailer bag, a shipping carton and a garment polybag are likely to count as three types, each with its own declaration; the reporting does not define the term, so confirm the split with your supplier or adviser. Second, an identification element on the packaging itself: a type, batch or serial number. Third, restrictions on substances, including limits on PFAS in packaging that touches food. Fourth, a duty on suppliers to give manufacturers the data needed to prove conformity. If you buy your boxes rather than make them, this is the duty that does most of the work for you. The documentation is kept for five years for single-use packaging and ten years for reusable packaging. The detail of these duties is as reported in compliance publications; the regulation and its dates are from the text.
Later dates
The harmonised labelling under Article 12 applies no earlier than 12 August 2028. A QR code on reusable packaging comes no earlier than 12 February 2029. As reported, a cap on empty space, 50 per cent, comes from 2030. The label is still two years away at the earliest; the declaration and the identification element already apply.
The label is 2028 at the earliest. The declaration behind each box is now.
Warehouse work
In a warehouse it takes a list of every packaging type in use, with a supplier and a declaration against each; a way to read the identification element on a pack, which usually means the supplier prints it and you record the batch you received; and a file that will still be there in five years, or ten for reusable crates. The work is light, but the list goes out of date when a buyer switches mailer supplier, so keep it with the packaging purchase order rather than in a compliance folder.
The empty-space cap is further away, but it is the one that changes operations. As reported, a cap of 50 per cent on empty space applies from 2030, and a carton that is mostly air will be the one to look at. Carton selection, the choice of box size against the items in an order, becomes a rule rather than a packer's habit, and the weight and dimensions you already hold per item are the data it runs on.
Packaging and the passport
The passport describes the product and the packaging has its own paperwork, but the two codes travel together. On Next Horizon, a product's passport can carry its packaging's composition for the sorting centre, and a carton-level code can resolve to every passport inside the box, so the pack is received in one scan. That is our method; neither regulation requires it. The care label, the QR and the RFID tag describes the product side. Until the Article 12 label applies, the packaging side is the declaration and the identification element.
Questions we get asked.
Do we need the new packaging label on our boxes now?
No. The harmonised label under Article 12 applies no earlier than 12 August 2028. As reported, the declaration of conformity per packaging type and the identification element on the pack apply now.
We buy our mailers from a supplier. Who does the paperwork?
As reported, the supplier has a duty to give the data needed to prove conformity, and the declaration is per packaging type. Ask the supplier for the data with every order and keep it with your own records.
How long do we keep the documentation?
As reported, five years for single-use packaging and ten years for reusable packaging.
Does this reach a small brand?
The texts we rely on give no size exemption. If you ship parcels in the EU, assume it reaches you and confirm with your adviser.
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