DECISION BRIEF
What the rule requires
Regulation (EU) 2025/40 covers all packaging and packaging waste placed on the EU market regardless of material or origin. It entered into force on 11 February 2025 and starts to apply on 12 August 2026. It sets requirements on the manufacturing, composition and reusable or recoverable nature of packaging; restricts per- and polyfluoroalkyl substances in food-contact packaging above defined thresholds; restricts certain single-use plastic formats such as individual portions and sachets of condiments and sauces; requires take-away businesses to accept consumer-supplied containers at no extra cost; and requires all packaging on the EU market to be recyclable in an economically viable way by 2030, with more recycled plastic and less virgin material.
The Ecodesign for Sustainable Products Regulation, Regulation (EU) 2024/1781, entered into force on 18 July 2024 and creates the digital product passport. It is a framework: the substantive product duties arrive through delegated acts per product group, and the Commission adopted the first ESPR and Energy Labelling Working Plan in April 2025 to fix which groups come first. It also bans the destruction of unsold apparel and footwear, with the detailed delegated and implementing regulations adopted on 9 February 2026.
Who is affected, and from when
Built for: EU exporters and their product, packaging, quality, procurement and compliance teams, together with manufacturers and converters supplying them.
A Turkish exporter is reached through the economic operator that places the product on the Union market. In practice the requirement arrives as a specification from the EU customer, and packaging is the first place it lands because it applies to everything, not to a listed product group.
For ESPR the timing depends entirely on which product group your goods fall into and when its delegated act applies. Net Zero does not assert a start date for the digital product passport here, because the official ESPR page does not state one — the working plan is the thing to watch, and it is tracked below.
The apparel and footwear destruction ban is already through its detailed rules, so brands with Turkish manufacturing partners are changing unsold-stock practice now.
What to do next
- Inventory packaging formats and materials per SKU, including secondary and transport packaging, so each PPWR requirement can be mapped to a defined product and evidence owner.
- Ask converters for recyclability evidence and recycled-content figures in writing; by 2030 economically viable recyclability is the market-access condition.
- Check PFAS in any food-contact packaging against the thresholds now — reformulation runs on a longer clock than the compliance date.
- Track the ESPR working plan for your product group rather than waiting for a passport deadline that has not been set.
Coverage boundary
This hub focuses on product-level circularity and EU market access. Türkiye’s domestic waste and extended-producer-responsibility regime is not restated here.