Regulation (EU) 2025/40 does not arrive all at once. Substance limits, declarations and producer registration bite first; recyclability grading, recycled content and the empty-space cap follow in 2030. Several rules still depend on acts the Commission has not adopted — those are marked, not guessed.
| Date | Scope | Article | Obligation | Status |
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"Act pending" means the obligation exists but the detail depends on a delegated or implementing act that has not been adopted. Any calculation in the app that rests on one is flagged provisional and names the act.
12 August 2026 is when packaging placed on the EU market needs a technical file, a declaration of conformity, a type, batch or serial number on the pack that allows the packaging to be identified (or in an accompanying document where the pack is too small), and a producer registration wherever you count as a producer under Art 3(1)(15). None of that can be produced retrospectively for stock already on shelves.
Heavy metals summed to 100 mg/kg in the packaging or packaging component (Art 5(4)), and PFAS limits on food-contact packaging with no stock-exhaustion transition.
A type, batch or serial number that allows the packaging to be identified, plus manufacturer/importer name and postal address — on the pack, a QR code/data carrier, or an accompanying document where permitted.
Producer registration where you are a producer under Art 3(1)(15), and an authorised representative for extended producer responsibility in each Member State where you supply direct to end users without being established there (Art 45(3)) — distinct from the Art 17 authorised representative.
Import your products and the audit workflow shows, per SKU, which of these obligations you already meet and which are open.