From 1 January 2030, Article 25 of the EU’s Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, prohibits packaging in six specified formats and uses. For product brands, the redesign decision depends on three things together: the packaging’s material, the function it performs and the setting in which it is used.
A plastic retail multipack may need a different grouping structure. A hotel toiletry may need a different dispensing arrangement: the accommodation restriction covers the specified single-use packaging regardless of material, so switching to paper can leave the restricted use intact. Premium paper boxes and ecommerce packaging face separate minimisation and empty-space requirements. Their redesign calendar includes a sales-packaging deadline as early as 12 February 2028.
The six packaging restrictions in Annex V
The PPWR has generally applied since 12 August 2026 and covers packaging placed on the EU market regardless of manufacturing origin. The following Article 25 restrictions have their own start date of 1 January 2030. The HORECA entries concern hospitality, restaurant and catering settings.
| Packaging format | Restricted use | Conditions and exceptions |
|---|---|---|
| 1. Single-use plastic grouped packaging | Point-of-sale grouping of goods sold in bottles, cans, tins, pots, tubs or packets, designed as convenience packaging to enable or encourage consumers to buy more than one product. Examples include collation film and shrink wrap. | Grouped packaging necessary to facilitate handling is excluded. |
| 2. Single-use plastic packaging for unprocessed fresh fruit and vegetables | Pre-packed fresh fruit and vegetables weighing less than 1.5 kg, including relevant nets, bags, trays and containers. | Member States may establish exemptions for a demonstrated need to prevent water or firmness loss, microbiological hazards, physical shocks or oxidation. A further exception concerns preventing organic and non-organic produce from mixing where no other option meets EU organic certification or labelling requirements without disproportionate economic and administrative costs. |
| 3. Single-use plastic food and beverage packaging in HORECA | Food and beverages filled and consumed on the premises. Eating areas include indoor, outdoor, standing and shared areas. | Establishments without access to drinking water are exempt. Member States may also allow qualifying micro-enterprises a derogation where it is demonstrated that avoiding the packaging, or obtaining access to infrastructure necessary for a reuse system, is technically infeasible. |
| 4. Single-use plastic portion packaging in HORECA | Individual portions of condiments, preserves, sauces, coffee creamer, sugar and seasoning. | Exceptions cover portions supplied with takeaway ready-prepared food intended for immediate consumption without further preparation, and packaging required for safety and hygiene in establishments providing medically necessary individualised care, such as hospitals, clinics or nursing homes. |
| 5. Single-use accommodation toiletries packaging | Packaging for cosmetics, hygiene and toiletry products intended for an individual booking and to be discarded before the next guest arrives. Examples include shampoo and lotion bottles and wrappers around bar soap. | This entry is not limited to plastic. Its scope follows the product and the intended accommodation use. |
| 6. Very lightweight plastic carrier bags | Very lightweight plastic carrier bags, such as thin bags supplied for loose groceries. | Exceptions cover bags required for hygiene reasons or supplied as sales packaging for loose food where this helps prevent food waste. |
These uses call for different replacement routes. Selling produce loose shifts protection towards display and handling arrangements; a replacement tray still needs to protect the particular fruit or vegetable. Reusable food-service vessels require collection, washing and storage arrangements. Moving condiment portions into dispensers changes how staff replenish products and control hygiene. The replacement succeeds when the packaging and the way it is used are developed together.
Destination-country rules also matter. Article 25 allows Member States to maintain restrictions adopted before 1 January 2025 on the same formats and uses made from materials not listed in Annex V. A material change therefore needs checking against the intended EU markets. Article 25 also requires further explanatory guidelines by 12 February 2027; its 1 January 2030 restriction date is fixed.
Retail multipacks: preserve the useful grouping function
Two individually sold cleanser bottles bundled in shrink film for a multibuy promotion illustrate the consumer convenience grouping described in Annex V. The handling exclusion depends on whether the grouping is necessary to facilitate handling in its actual use. A transport bundle and a promotional pack offered to shoppers therefore need separate assessments, even if both use similar film.
Recycled plastic film retains the material and use characteristics relevant to this restriction. Paper alternatives also need a composition review. The Commission’s guidance on plastic content and packaging bans includes paper-based composites containing more than 5% plastic by mass within points 1–4 of Annex V. Review the actual laminate and component specification when choosing a replacement. The Single-Use Plastics Directive may also apply to packaging outside these Annex V restrictions.
The structural choice starts with what the grouping layer must accomplish. Two products already protected by individual cartons may only need to stay together as one purchase. Two exposed glass bottles may also need restraint and separation so they cannot strike each other. That difference determines whether a narrow band is enough or whether a carrier or carton earns its additional material.
- A locking paperboard band or sleeve can hold regularly shaped cartons together while leaving much of the original branding visible. Smooth or tapered bottles require more deliberate retention: an open band can let a bottle slide out when the pack tilts. Locking features, contact areas and opening tabs need development around the actual product.
- A paperboard carrier can locate bottles or cans through shaped openings and supporting panels while keeping the products visible. The load must pass through parts strong enough to carry it. Product dimensions, grip position and expected moisture exposure affect whether the carrier stays secure in a shopper’s hand.
- A closely fitted folding carton with paperboard partitions offers space to separate fragile products and carry the set’s graphics and information. It can suit bottles that need protection beyond simple grouping. Its extra panels, assembly work and effect on product visibility should be weighed against that protection.
At CMIC, we can develop these alternatives around the real products and their expected dimensional variation. A sleeve that grips one sample tightly may loosen around a smaller bottle or scuff a larger one. Samples make those differences visible through lifting, tilting, handling and opening. Appropriate transport evaluation can then address the distribution route. Comparing assembly time, product access, barcode visibility and any additional shipping protection gives the brand a useful basis for choosing between structures.
Hotel toiletries: change how the product is supplied and dispensed
Annex V point 5 covers single-use cosmetics, hygiene and toiletry packaging intended for one accommodation booking and disposal before the next guest arrives. A paper wrapper around guest soap or a glass miniature can fall within that description. The entry contains no bottle-volume threshold: increasing the size while retaining the same intended use does not resolve the restriction. Travel-size cosmetics sold through retail have a different use and must be assessed accordingly.
A useful starting point is deciding what remains in the room across bookings. A dispenser replenished from a larger supply container can support repeated use, but the development work extends to the formulation and housekeeping procedure. The lotion must flow through the selected pump; the container and seals must suit the product; and staff need a workable method for replenishment, cleaning and product identification. These choices should be developed with the cosmetic supplier and accommodation operator.
A durable dispenser with a sealed replacement refill offers another route to explore. It changes the replenishment operation and introduces a refill package that needs its own assessment. Capacity, residual product, replacement frequency and the material in cartridges and closures all affect the result. A durable outer holder does not settle the status of a single-use insert intended to be discarded after every booking.
The guest experience deserves the same attention as replenishment. Clear product names, a pump that works comfortably with wet hands and a dispenser that remains presentable through repeated use can carry the brand’s quality. We can coordinate suitable component partners alongside paper secondary packaging, bringing dispenser fit, refill dimensions, transit protection and printed instructions into a shared development brief.
Where the proposed route relies on reusable packaging, Article 11 requires design for repeated use, safe emptying and refilling, suitable reconditioning and continued product protection, among other conditions. The operating arrangements must support that repeated use. A reusable description on the specification needs a practical system behind it.
Premium paper boxes: justify the weight, volume and layers
For retail fragrance, skincare and other gift boxes, Article 10 raises a separate design question. From 1 January 2030, packaging weight and volume must be reduced to the minimum necessary to ensure functionality, taking account of its shape and material. Features aimed only at increasing the perceived product volume—including double walls, false bottoms and unnecessary layers—are targeted by the restriction.
Annex IV recognises packaging functionality associated with gifts and seasonal occasions. It also recognises protection, manufacturing, logistics, information, hygiene and safety requirements. However, marketing and consumer acceptance no longer serve on their own as reasons for extra weight or volume. A premium presentation therefore benefits from precise proportions, considered surfaces and a satisfying opening movement, with the structure supporting a clear function.
Consider a fragrance box with a paperboard insert around a glass bottle. Restraining the bottle and keeping it from striking the lid are useful functions. Development can test whether a lower insert or shallower box performs those functions reliably across normal product and manufacturing tolerances. A raised platform whose only purpose is to make the bottle appear larger has a different basis. The assessment concerns what the feature does and whether its dimensions are necessary.
We can develop sample variations in box height, insert geometry and board construction, then coordinate evaluation of the functions that limit further reduction. The resulting evidence should connect the retained dimensions and materials to their purpose. Article 10 and Annex IV require the assessment, relevant design constraints and supporting tests, studies or other evidence in the technical documentation, including consideration of production-batch variation. Replacing one material with another alone is insufficient; reduction opportunities within the chosen material also need investigation.
Article 10 contains specific exceptions for qualifying EU geographical indications and quality schemes, and for certain design rights or shape trademarks protected before 11 February 2025. For the latter, applying the requirements must affect the design’s novelty or individual character, or the trademark’s ability to distinguish the product. These conditions require assessment against the particular protected design or mark.
Ecommerce and sales packaging have different empty-space rules
Article 24 distinguishes the sales packaging that forms the product’s retail unit from the grouped, transport or ecommerce packaging around it. By 12 February 2028, operators filling sales packaging must reduce its empty space to the minimum necessary for functionality, including product protection. This requirement has no universal 50% allowance. A skincare carton or gift box therefore needs a functional assessment of its own space.
For operators filling grouped, transport or ecommerce packaging, Article 24 sets a maximum empty-space ratio of 50%. It applies from 1 January 2030 or three years after the relevant implementing acts enter into force, whichever is later. The Commission must establish the calculation methodology by 12 February 2028, taking account of protection, legal requirements and other specified practical needs. This timing dependency does not postpone the fixed Article 25 format restrictions.
The basic relationship is the outer packaging’s total volume minus the volume of the sales packaging contained inside it, divided by the outer packaging’s total volume. Void fill counts as empty space, including paper cuttings, air cushions, bubble wrap and foam. Changing the filler material leaves that part of the calculation unchanged.
For an illustrative design comparison, assume an order contains retail cartons with a combined volume of 2.4 litres inside a 6-litre shipping box. The simplified calculation is (6 − 2.4) ÷ 6, or 60% empty space. A 4-litre shipper would give 40% on the same assumptions. The smaller format still has to accommodate the cartons and necessary protection; final compliance measurements must follow the Commission’s methodology. The practical opportunity is often a better choice of shipping-box sizes for the orders customers actually place.
The 50% cap has exemptions for sales packaging used directly as ecommerce packaging and for reusable packaging used within a reuse system. Weight and volume minimisation still matter. A product box designed to ship directly may remove an outer layer, provided its closure, surfaces and structure suit the journey. A sturdy gift box that a customer might keep for storage does not, by that possibility alone, establish a packaging reuse system.
Turn the restriction into a workable replacement
A replacement needs its own material and construction assessment. Coatings, barriers, attachments and ease of separating components can affect recycling. The Commission interprets Article 6’s general recyclability requirement as applying from 12 August 2026; the detailed design-for-recycling requirements apply from 1 January 2030 or 24 months after the relevant delegated acts enter into force, whichever is later. Choosing a route outside a particular Annex V restriction is one part of developing the finished package.
Give early development time to changes that affect filling, dispensing or retail handling. A hotel refill arrangement needs the product supplier, accommodation operator and component suppliers to agree how it works. A retail multipack needs agreement on retention, shelf presentation and packing operations. Those decisions shape the samples and evaluations required before production approval.
- Define the intended use. Record where the pack is sold or supplied, who handles it and what happens to it after use. Separate retail, accommodation and transport uses where the same product appears in several channels.
- Compare complete packaging arrangements. Include inserts, bands, closures and any extra shipping protection required by a proposed change. A simpler outer appearance can conceal additional components elsewhere.
- Evaluate with real products. Use representative dimensions and weights, expected handling conditions and the actual opening or dispensing operation. Record why the selected structure and material quantities are needed.
- Carry the decision into production. Approved dimensions, material specifications, component versions and acceptance criteria should describe the same package that was evaluated.
Stock planning also needs the correct reference point. Article 25 addresses placing packaging on the EU market. For packaging sourced from China, a factory order or production date does not by itself establish when that event occurs. Map the relevant supply chain and packaging type, then work backwards through approvals, filling, shipping and delivery. That gives the changeover a usable timetable without assuming that all stock produced before 2030 receives the same treatment.
Our EU packaging solutions bring structural development, materials, sampling and suitable specialist coordination into the same project. To begin a review, contact us with the current packaging, product details, intended EU markets and how the product is sold or used. We can use that information to develop a small number of practical alternatives, with the differences in protection, presentation, handling and production made clear.
