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Requirement · REU-01

Meet all nine reusability criteria before packaging counts as reusable: designed for multiple rotations, emptiable and refillable without damage, reconditionable per Annex VI Part B, labellable, safe to handle, and recyclable at end of life.

Manufacturers of reusable packaging must comply, and this is law in force.

Why it matters

This is law in force, not a proposal.

  • It is Art. 11(1), in the Packaging and Packaging Waste Regulation. as of 2026-08-18
  • The act gives its timing as: From 11 February 2025 (Art. 11(1)). as of 2026-08-18
  • It names 7 industries by name: Plastics converting, Paper and board, Glass, Aluminium, Wood, Food and drink and Retail. as of 2026-08-18
  • Compliance is checked by technical documentation (Annex VII), per packaging design. as of 2026-08-18
Addressee Manufacturers of reusable packagingAct Regulation (EU) 2025/40, base actArticle Art. 11(1)Class Businesses

What changes

Anyone counting packaging towards the Art. 29 re-use targets. Note the date: this definition binds from 11 February 2025, well before the Regulation generally applies on 12 August 2026, so packaging placed on the market in the interim is already being measured against it.

The rule

New — no predecessor
Trigger

packaging claimed or counted as reusable

Obligation

Meet all nine reusability criteria before packaging counts as reusable: designed for multiple rotations, emptiable and refillable without damage, reconditionable per Annex VI Part B, labellable, safe to handle, and recyclable at end of life.

Who is affected

Addressee
Manufacturers of reusable packaging
Class
Businesses
Sectors
Names Plastics converting, Paper and board, Glass and ceramics, Aluminium and metals, Wood and wood products, Food, drink and tobacco, Retail and distribution · Reaches Waste and landfill
Applies
From 11 February 2025 (Art. 11(1))

Burden drivers

D1 · D4 — 2 of 7 marks fire on this provision.

No size threshold.

Source text

Verbatim

Packaging placed on the market from 11 February 2025 shall be considered to be reusable where it fulfils all of the following requirements: (a) it has been conceived, designed and placed on the market with the objective to be re-used multiple times; (b) it has been conceived and designed to accomplish as many rotations as possible under normally predictable conditions of use; (c) it fulfils applicable requirements regarding consumer health, safety and hygiene; (d) it can be emptied or unloaded without being damaged in a way that would prevent its further function and re-use; (e) it is capable of being emptied, unloaded, refilled or reloaded while maintaining the quality and safety of the packaged product and ensuring compliance with the applicable safety and hygiene requirements, including those on food safety; (f) it is capable of being reconditioned in accordance with Part B of Annex VI, while maintaining its ability to perform its intended function; (g) it allows for affixing of labels and the provision of information on the properties of that product and on the packaging itself, including any relevant instructions and information for ensuring safety, adequate use, traceability and shelf-life of the product; (h) it can be emptied, unloaded, refilled or reloaded without risk to the health and safety of those responsible for doing so; and (i) it fulfils the requirements specific to recyclable packaging set out in Article 6, so that it can be recycled when it becomes waste.

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Settled later in secondary legislation. The minimum number of rotations for the most-used reusable formats is set by delegated act due 12 February 2027 (Art. 11(2)). Until then criterion (b) has no number behind it.