The document and its dates

  • Regulation (EU) 2025/40 on packaging and packaging waste. In force since 11 February 2025; applies from 12 August 2026.
  • On the same date, the earlier Packaging and Packaging Waste Directive 94/62/EC was generally repealed, with some of its provisions continuing to apply afterwards.
  • The Commission published a guidance document for the regulation, C(2026)3702, in March 2026, and a set of frequently asked questions in August 2026. Both interpret the regulation; the regulation itself is the binding text.

The application date is not in the future. Any consignment that has entered the EU since 12 August 2026 is already inside the new regime rather than approaching it, which changes the framing of the question from "will this affect us" to "which of these obligations already apply".

What it asks of packaging

The Commission's own summary of the regulation describes requirements across the packaging life cycle. Three of them are close enough to a towel shipment to be worth naming:

  • Restrictions on certain single-use plastic packaging formats. The regulation restricts specific formats, and the Commission's example is individual portions and sachets of condiments and sauces. Whether a given format is caught is a question about the format and its use, and the guidance document treats the scope of the bans at length.
  • Substances of concern. The regulation minimises substances of concern in packaging, including restrictions on PFAS in food-contact packaging above set thresholds. A towel is not a food, so food-contact packaging is not the obvious application — but a supplier asked for a packaging declaration will want to know which thresholds were assessed and which were not.
  • Recyclability, recycled content and labelling. The stated aim is that all packaging on the EU market be recyclable in an economically viable way by 2030, alongside requirements on recycled content and harmonised labelling.

These do not all begin on the same day. The Commission's guidance document has a section dedicated to the date of application of the recyclability requirement, which is a plain signal that the obligations run on different clocks and that some depend on implementing acts still to be adopted.

The role question, which is a contract question

The regulation attaches obligations to defined roles rather than to materials: manufacturer of packaging, producer, importer, and so on. The guidance document devotes separate sections to defining each of them, which tells you something about how much turns on the definitions.

For an export arrangement, which party holds which role follows from who places the packed product on the EU market and under what brand. It does not follow from who physically puts the towel in the bag. That makes it a contractual question before it is a technical one, and the useful output of reading the guidance is a short written statement in the purchase agreement: who is the producer for the packaging, who holds the supporting documentation, and who answers if a national authority asks.

One moving part is worth knowing about before anyone prices compliance. In December 2025 the Commission proposed, as part of its environmental omnibus, to suspend the obligation for producers to appoint an authorised representative when selling packaged products directly to consumers in a Member State other than their own. The Commission's page states that the proposal is still being examined by the European Parliament and the Council. A requirement that may be suspended or reshaped is a poor basis for a fixed commitment, so check its current state before building it into a price.

What this does not mean

  • It does not mean a towel is regulated as packaging. The product and its packaging are different objects under this regulation, and the obligations attach to the packaging.
  • It does not mean every obligation started on 12 August 2026. Some are phased, and several depend on acts not yet adopted.
  • It is not legal advice and it is not a statement that any shipment complies. This site has no view on the compliance of a specific consignment, and an entry here should not be read as one.