2026-08-10

A broad new European Union packaging rule will begin to apply across the bloc on Wednesday, setting off changes that will reach breweries, wineries, distilleries and drinks exporters far beyond Europe. The measure, formally known as Regulation (EU) 2025/40 on packaging and packaging waste, covers all packaging sold in the EU, from bottles and cans to labels, caps, sleeves, shipping boxes and e-commerce materials.
The regulation entered into force in February 2025, but most of its general obligations start to apply on Aug. 12, 2026. Unlike the older EU packaging directive, this is a regulation, which means it applies directly in all 27 member states. That does not remove national differences. Companies will still have to deal with country-by-country producer responsibility systems, deposit programs, registration rules, labels, languages, enforcement agencies and penalties.
For the drinks business, the law matters because it does much more than address trash collection. It ties access to the EU market to a growing set of packaging conditions, including limits on substances of concern, packaging minimization, recyclability, recycled plastic content, reuse, labeling, technical documentation, traceability and extended producer responsibility fees. The European Commission’s stated aim is to reduce unnecessary packaging, make packaging recyclable or reusable, and align rules inside the single market.
Beer faces the clearest direct pressure among alcoholic drinks. Under the regulation, final distributors such as stores, bars, restaurants and online sellers will, in principle, have to make at least 10% of covered beverages available in reusable packaging by 2030. Commission guidance says that target is about availability, not necessarily 10% of actual sales. A returnable bottle offered to shoppers can count toward the target. A reusable keg sent to a bar usually does not, because the consumer does not receive the keg.
Most wine categories, aromatized wine drinks, many other fermented beverages under customs code NC 2206, and spirits under NC 2208 are expressly excluded from that specific 10% beverage reuse target. But that exemption is narrow. It does not free wineries and distilleries from the rest of the regulation. They still face the rules on weight reduction, recyclability, labeling, technical files, EU declarations of conformity, registration and waste financing.
That distinction is likely to reshape packaging decisions in premium wine and spirits. From 2030, companies will have to show that the weight and volume of packaging are no more than what is needed for product protection, hygiene, transport, legal information and other essential functions. Thick glass bases, double walls, false bottoms and layers added mainly for appearance are likely to face closer scrutiny. The regulation allows limited exceptions for some protected designs and certain geographical indications that predate Feb. 11, 2025, but those are not broad exemptions for all heavy or ornate bottles.
Another major change is the EU’s collection target for beverage containers. Plastic beverage bottles and metal containers of up to 3 liters must reach annual separate collection of at least 90% before 2029, usually through deposit-return systems. Beer sold in cans or plastic bottles falls squarely into that regime. Many wine categories, other fermented beverages in NC 2206 and spirits in NC 2208 are excluded from the EU’s minimum deposit mandate, but member states are allowed to go further. That means a wine or spirit can be outside the EU minimum rule and still end up in a national deposit system if a country expands its program.
That is one reason the drinks trade is watching national differences as closely as the EU text itself. Germany, the Netherlands and several Nordic and Baltic countries already have established deposit systems. Other countries are expanding or preparing them. Malta, for example, includes glass, PET, aluminum and steel in its deposit system. Spain has combined packaging obligations with a national tax on non-reusable plastic that does not include recycled plastic content. France has its own broad producer responsibility framework and transitional labeling rules, which will have to adapt when the EU’s harmonized label system arrives.
The regulation also reaches suppliers outside Europe. A winery in California, a brewer in Mexico, a Scotch whisky bottler in Britain or a rum producer in the Caribbean may be thousands of miles away from Brussels, but if the product is sold in the EU, the packaging must comply. EU importers will need data on composition, substances, recyclability, recycled content, weight and conformity. In some cases, non-EU companies may also need authorized representatives for producer responsibility systems in the countries where their packaging first enters the market.
British authorities have already warned exporters that non-compliant goods can be rejected. That warning is likely to resonate across other export markets, including the United States. Importers are expected to tighten contracts, ask for technical files earlier and shift more responsibility to suppliers. Online platforms and logistics operators may also suspend sellers that cannot prove the required producer responsibility registrations in the countries where they sell.
Some of the hardest work will happen at the level of a single stockkeeping unit. A company cannot treat this as one broad sustainability policy for all products. It must know, for each bottle or can sold in each country, the product category, customs classification, full packaging structure, weight of every component, whether the packaging is reusable or single-use, expected recyclability, recycled plastic content, first market of sale, deposit rules, language needs and the legal entity responsible for compliance.
Several technical deadlines are still ahead. The regulation requires packaging to be designed for recycling by 2030, with recyclability to be graded A, B or C once the EU adopts the relevant secondary rules. From 2038, packaging with a C grade will no longer be allowed. Single-use plastic beverage bottles are expected to contain at least 30% post-consumer recycled plastic from 2030, or later if the related implementing act is delayed. The law also requires companies to minimize substances of concern and sets PFAS limits for food-contact packaging, which means drinks companies must look not just at the bottle body but also at can linings, cap liners, inks, adhesives, films, valves and bag-in-box components.
Labeling is another coming challenge. Harmonized EU pictogram-based labels on material composition are due from Aug. 12, 2028, or later if secondary acts are adopted after that. Reusable packaging will also need a specific marking and a digital carrier, such as a QR code, with information on the return system and other details. During the transition, national labels may coexist in some markets, but once the EU label applies, member states will not be able to keep incompatible national markings alongside it.
There is no new EU customs tariff attached to the regulation. The costs come in other forms: producer responsibility fees, deposit system access charges, testing, redesign, new molds, data management, label changes, legal reviews and reverse logistics. Planning scenarios circulating in the sector suggest that incremental annualized costs could run at roughly €0.01 to €0.07 per liter for large groups, €0.02 to €0.16 per liter for midsize producers and €0.04 to €0.40 per liter for smaller operators, depending on packaging complexity, the number of markets, the number of SKUs and whether a company must build a returnable system from scratch. Those figures are not official rates, but they help explain why the rule is already influencing investment decisions.
Beer producers may be better placed than other alcohol sectors to adapt, at least in operational terms, because returnable glass bottles, reusable crates and steel kegs are already familiar formats. Still, the economics depend on rotation rates, return distances, washing capacity and loss rates. A local returnable bottle pool can work very differently from a brand-specific bottle shipped across borders. For wine, the largest pressure point may be bottle weight rather than mandated reuse. Lighter bottles, more recycled glass, simpler decorations and, in some cases, alternative formats such as bag-in-box or cans are likely to gain attention. For spirits, the issue is less about deposit mandates and more about whether premium packaging can keep its look while meeting the rules on minimization and recyclability.
The regulation’s legal start date this week does not mean every requirement lands at once. Much of the system is staged through 2028, 2029 and 2030, with later thresholds after that. But companies that wait for the final deadlines may find themselves boxed in by long lead times for molds, labels, technical validation and national registrations. Importers, retailers and distributors are already in a position to refuse products that lack the basic compliance documents required to place packaging on the EU market.
For many drinks companies, the immediate task is not choosing one “winning” material. It is building a market-by-market compliance map before products move. That means checking customs codes for borderline categories such as ready-to-drink cocktails and hard seltzers, collecting supplier declarations for every component, reserving label space for future EU pictograms, and confirming which cans, bottles and multipacks will need deposit registration in each country before they are offered for sale.