11 February 2025 and 12 August 2026
The Regulation entered into force on the twentieth day after publication: 11 February 2025. Article 71 provides that it applies from 12 August 2026, subject to the stated exception for Article 67(5).
From the general application date, the manufacturer, importer and distributor duties and the applicable Articles 5–12 requirements need to be assessed. For example, the Article 5(5) limits for PFAS in food-contact packaging apply from 12 August 2026, subject to their terms and overlap rule.
Important later milestones
The Regulation phases in several design, recycled-content, labelling, reuse and waste-management measures. The operative date can be a fixed date, a number of months after an implementing act enters into force, or whichever of the two is later.
- Harmonised material-composition labelling: from 12 August 2028 or 24 months after the relevant acts enter into force, whichever is later
- Reusable-packaging labelling: from 12 February 2029 or 30 months after the relevant act, whichever is later
- Design-for-recycling performance grades: staged from 2030, with the detailed methodology set by delegated acts
- Minimum recycled-content targets for plastic packaging: staged from 2030
- Recyclability-at-scale condition: staged from 2035
How to manage a changing timeline
Keep current requirements separate from future planning items in the technical file. Record the legal basis, trigger and source review date instead of treating a target year as a complete instruction.
Review the Commission guidance, implementing and delegated acts, and packaging-specific exceptions before changing artwork, specifications or assessments.
This timeline is a working overview. The precise rule can depend on packaging type, use, exemptions, the date an implementing act enters into force and transitional provisions.