For several years now, the European Union has been working towards a more sustainable and responsible production model. This includes promoting the circular economy, harmonizing labelling requirements, and reducing both waste generation and the use of certain materials. To achieve this, EU legislation increasingly requires Member States to push companies towards more conscious and sustainable business decisions.
The new Regulation UE 2025/40, which came into force in early 2025, includes a phased implementation timeline. Looking ahead to 1 January 2030 (with further obligations beyond that date), the main milestones include:
a) Companies are expected to prioritize the reduction of substances of concern—generally understood as those harmful to human health and the environment—and to place recyclable packaging on the market.
b) August 2026: Packaging intended to meet food may no longer be placed on the market if it contains per- and polyfluoroalkyl substances (PFAS) above the limits set out in the Regulation.
c) February 2027: Deadline for Member States to establish the final administrative sanctions framework.
d) August 2028: Entry into force of the harmonized EU labelling system.
e) January 2030: Among other measures, the plastic components of packaging placed on the market must contain a minimum percentage of recycled material.
All the above applies without prejudice to full compliance with the relevant Spanish legislation.
In this context, it is both advisable and necessary for affected companies—those placing packaging on the market—to continue assessing their level of compliance and to define a realistic action plan that allows them to meet regulatory requirements at both national and EU level.
At addwill, we support companies throughout this adaptation process, helping them address any legal questions that may arise.