EU Packaging Regulation Replaces 32-Year-Old Directive
EU Packaging Regulation 2025/40 has applied directly in every member state since August 12. Serbian exporters now need an authorized representative in each country where they sell goods.
EU Regulation 2025/40 on packaging and packaging waste has applied since August 12, 2026, replacing directive 94/62, which had been in force since 1994. For Serbian exporters, the change is not only in the content of the rules but in their legal form. A directive gets transposed into each member state’s national law and ends up with its own local version, while a regulation applies directly and identically across the entire Union, from the same day, with no translation into domestic legislation required.
The practical consequence is that there is no longer any transition period. A company shipping packaged goods to the EU market today needs its paperwork ready, not still in the works.
What exporters need to have in place today
The regulation makes no distinction between a producer based in the Union and one outside it. Whoever places packaging on the EU market carries the same obligations as a company registered in one of the member states, and three of those obligations took effect immediately.
- an authorized representative in every member state where the goods are placed on the market, with separate registration required for each one, and no option to file a single EU-wide registration
- a declaration of conformity and technical documentation for every type of packaging, with traceability guaranteed through the supply chain
- registration in the extended producer responsibility scheme of every member state where the goods are sold
For packaging that comes into contact with food, a limit of 25 parts per billion now applies to individual perfluorinated and polyfluorinated substances, and 250 parts per billion to the sum of those substances. In e-commerce, empty space inside a shipment is capped at 40 percent, a rule that also covers companies selling directly to EU customers through their own website.
Who pays the most
The food and beverage industry carries the heaviest burden, since it faces both requirements at once: its packaging is in direct contact with food and falls under the limits on fluorinated substances. Cosmetics and household chemical producers come next, along with domestic packaging manufacturers, who now have to supply documentation to their exporter clients.
The cost is not a one-off expense, and it is not limited to paperwork. A representative has to be contracted separately in each member state, and extended producer responsibility fees are paid under national schemes, so an exporter supplying five countries ends up with five registrations and five separate bills, not one.
Serbian Chamber of Commerce support
The Serbian Chamber of Commerce has launched an expert support program to help companies apply the new regulation, working together with the Swiss export promotion program known as SIPPO and with backing from the Swiss State Secretariat for Economic Affairs. The program targets small and medium-sized enterprises above all and includes two digital tools, one for assessing packaging compliance and another for preparing technical documentation. Use is free for chamber members, subject to mandatory registration.
Dušanka Kalezić, advisor to the president of the Serbian Chamber of Commerce, explained in a chamber statement why the service launched now:
That is precisely why the Serbian Chamber of Commerce, together with the SIPPO program, launched an expert support program intended primarily for small and medium-sized companies that export or plan to export to the European Union market.
The third phase of that program runs from 2026 to 2029, a period that covers most of the deferred obligations the regulation introduces.
Which deadlines are still ahead?
The regulation is not a single date but a series of deadlines stretched out to 2040.
- February 12, 2027: member states must have national penalty frameworks in place for non-compliance
- August 12, 2028: harmonized packaging labeling and quick-read codes take effect
- January 1, 2030: recyclability rules and minimum recycled content requirements kick in
- January 1, 2035 and January 1, 2040: the same requirements tighten further
The next deadline is February 2027, when missing documentation stops being just a business risk and becomes an offense carrying a fine set by the country of delivery. For a Serbian exporter, that means competitiveness on the EU market is no longer measured by price and quality alone, but also by whether the packaging a product arrives in carries the papers to back it up.
