One order of branded takeaway cups for a chain trading in Germany, the Netherlands and the UK can touch a dozen legal terms before the first cup is filled. The chain may be the PPWR "manufacturer" of its own cups, the Dutch importer the "producer" for Verpact, the cups need "Plastic in product" marking, the truck to Germany travels with an A.TR, and the UK consignment needs an origin declaration instead. This packaging regulation glossary defines those terms, and more than 150 others, in the sense that EU, German, Austrian, Dutch, UK and US rules and freight documents actually use them.
How to use this glossary
Each entry is a standalone definition that can be read, quoted or shared without the rest of the page. The heading gives the term, its abbreviation and, where it helps, the German (DE), Dutch (NL), Austrian (AT), UK or US equivalent. Regulatory entries name the instrument, the jurisdiction and the date, reflect the position as of October 2026 and are definitions, not legal advice: obligations depend on a company's role (manufacturer, producer, importer, distributor) in each country and should be confirmed with the competent authority, the compliance scheme or counsel.
Terms are grouped into ten sections and listed alphabetically within each. Most entries end with a link to the 9 Packaging guide that covers the topic in depth. Short definitions of the most common terms also sit in the main packaging glossary; the sibling sub-glossaries cover printing and prepress, converting and manufacturing, materials and testing and quality.
EU packaging law: PPWR roles and documents
Who is responsible for what under Regulation (EU) 2025/40, and which documents follow from each role. The full picture is in PPWR explained for foodservice and e-commerce buyers.
Authorised representative (EU; PPWR; DE: Bevollmächtigter; NL: gemachtigde)
An authorised representative is a person established in the EU who acts on behalf of another company under a written mandate. The PPWR uses the term in two ways: a manufacturer may mandate a representative to hold its technical documentation, and a producer not established in a Member State where it supplies end users must appoint an authorised representative for extended producer responsibility (EPR) there. Legal responsibility for the packaging's conformity stays with the manufacturer.
See: PPWR explained; PPWR Declaration of Conformity
Commission guidance notice C(2026) 3702 (EU)
C(2026) 3702 is the European Commission's guidance document on Regulation (EU) 2025/40, dated 5 June 2026. It interprets key points such as who counts as manufacturer for service packaging, how the Article 5(5) PFAS limits are tested and which paper-based packaging falls under the Annex V bans. It is not legally binding; a binding interpretation can only come from the Court of Justice of the EU.
See: PPWR explained
Conformity assessment (EU; PPWR Module A, internal production control)
Conformity assessment is the procedure by which the PPWR manufacturer demonstrates that a packaging type meets Articles 5 to 12 of Regulation (EU) 2025/40 before placing it on the market. For packaging the procedure is Module A, internal production control, set out in Annex VII: the manufacturer prepares technical documentation, controls production so that series output matches it, and then draws up the EU Declaration of Conformity. No notified body is normally involved, and the assessment must be repeated when design, materials or referenced standards change.
See: PPWR Declaration of Conformity
Distributor (EU; PPWR)
A distributor is any operator in the supply chain, other than the manufacturer or importer, that makes packaging available on the market, such as a wholesaler or cash-and-carry. Under the PPWR it must check that packaging carries the required documentation and labelling and must not supply packaging it knows to be non-compliant. A distributor that puts packaging on the market under its own name, or modifies it in a way that could affect compliance, takes on the manufacturer's obligations (Article 21).
See: PPWR explained
Economic operator (EU; PPWR)
Economic operator is the PPWR's collective term for the businesses that carry obligations along the packaging chain, including the manufacturer, supplier, importer, distributor, authorised representative, final distributor and fulfilment service provider. One company can hold several roles at once, for example a chain that imports its own branded packaging is both manufacturer and importer, and its role can differ between Member States.
See: PPWR explained
EPR (extended producer responsibility; DE: erweiterte Herstellerverantwortung; NL: uitgebreide producentenverantwoordelijkheid, UPV)
Extended producer responsibility (EPR) makes the business that places packaging on a national market, the producer, responsible for financing its collection, sorting and recycling, usually by registering, reporting tonnages by material and paying fees to a scheme. The PPWR sets common EPR rules for the EU, but registration and fees are still run nationally: LUCID and dual systems in Germany, collection systems such as ARA in Austria, Verpact in the Netherlands. The UK and several US states run their own EPR schemes, and fees are increasingly modulated by recyclability.
See: PPWR explained; sourcing packaging from Türkiye
EU Declaration of Conformity (EU; PPWR; DE: EU-Konformitätserklärung; NL: EU-conformiteitsverklaring)
The EU Declaration of Conformity is the PPWR manufacturer's signed statement that a packaging type meets the applicable requirements of Articles 5 to 12 of Regulation (EU) 2025/40, following the model in Annex VIII and backed by Annex VII technical documentation. It must be in the language required by each Member State of supply, kept for 5 years for single-use and 10 years for reusable packaging, and checked by importers. It is a different document from the food-contact Declaration of Compliance.
See: PPWR Declaration of Conformity
Importer (EU; PPWR)
The importer is the EU-established operator that places packaging from a third country, such as Türkiye, on the EU market. Under Article 18 of the PPWR it must check that the manufacturer has carried out conformity assessment and drawn up technical documentation, that the packaging is labelled and identified as required, and add its own name and postal address on the packaging or an accompanying document. It keeps a copy of the Declaration of Conformity for 5 or 10 years and often also becomes the EPR producer in the country of first supply.
See: PPWR Declaration of Conformity; sourcing packaging from Türkiye
Manufacturer (EU; PPWR Article 3(1)(13); DE: Erzeuger)
Under the PPWR, the manufacturer is whoever manufactures packaging or has it designed or manufactured under its own name or trademark, so a chain ordering cups printed with its logo is normally the manufacturer even though a converter makes them. The manufacturer carries out conformity assessment, keeps the technical documentation and signs the EU Declaration of Conformity. A micro-enterprise brand owner can leave the role with a supplier established in the same Member State, but not with a supplier outside the EU, and national authorities are still settling how the definition applies to empty printed service packaging.
See: PPWR Declaration of Conformity; PPWR explained
Placing on the market and making available on the market (EU)
Placing on the market is the first supply of a packaging item for distribution or use on the EU market; making available on the market is any later supply in the course of a commercial activity, whether paid or free. The distinction matters because many PPWR obligations, and the 5- and 10-year document retention periods, attach to the moment packaging is placed on the market, which is usually when the importer or EU manufacturer first supplies it.
See: PPWR explained
PPWR (EU; Regulation (EU) 2025/40, Packaging and Packaging Waste Regulation)
The PPWR is the EU Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, in force since 11 February 2025 and generally applicable from 12 August 2026. As a directly applicable regulation it sets EU-wide rules on substances (including PFAS in food-contact packaging), recyclability, recycled content, compostability, minimisation, reuse, labelling, conformity documentation and EPR. Many design requirements phase in from 2028, 2030, 2035 and 2038 and depend on delegated and implementing acts the Commission is still adopting.
See: PPWR explained
Producer (EU EPR; PPWR)
In EPR, the producer is the operator that first makes packaging available on the market of a Member State and therefore registers, reports and pays fees there. For service packaging, this is the operator first making it available in that Member State; a third-country manufacturer selling directly to end users there is itself the producer and must appoint an authorised representative. Producer and manufacturer are separate roles that are often, but not always, held by the same business.
See: PPWR explained; packaging compliance in the Netherlands
Producer responsibility organisation (PRO; compliance scheme)
A producer responsibility organisation (PRO) is the body producers join or pay to meet their EPR obligations collectively: it collects fees, organises or finances collection and recycling, and reports to the authorities. Examples include the German dual systems, ARA and Reclay in Austria, Verpact in the Netherlands and the Circular Action Alliance in most US EPR states. UK pEPR fees are administered by PackUK, a government scheme administrator rather than a producer-run PRO.
See: sourcing packaging from Türkiye
Technical documentation (EU; PPWR Annex VII; DE: technische Dokumentation)
Technical documentation is the evidence file behind the PPWR EU Declaration of Conformity. Under Annex VII it describes the packaging and its intended use, its design, materials and components, the standards or specifications applied, how recyclability, minimisation and reusability were assessed, and the test reports relied on (for example PFAS or heavy-metal results), together with an analysis of the risks of non-conformity. The manufacturer keeps it for 5 years for single-use and 10 years for reusable packaging and supplies it to authorities on request.
PPWR packaging types and design requirements
The packaging categories the PPWR defines and the design, reuse and labelling rules that attach to them. Grades are explained in PPWR recyclability grades and labels in PPWR labelling requirements.
Annex V restrictions (EU; PPWR Article 25)
Annex V of the PPWR lists packaging formats that may not be placed on the market from 1 January 2030. It includes single-use plastic packaging for food and drink filled and consumed on HORECA premises, single-use plastic condiment portions in HORECA (except when supplied with takeaway food) and very lightweight plastic carrier bags (with exceptions). Commission guidance of 5 June 2026 treats paper-based packaging containing 5 % or more plastic as covered by the Annex V bans, and packaging with no more than 5 % as not covered; the guidance is not legally binding.
See: PPWR explained; paper vs plastic bowls
Composite packaging (EU; PPWR)
Composite packaging is packaging made of two or more different materials that cannot be separated manually and form a single integral unit, such as a PE-lined paper cup or a plastic-laminated board. Under the PPWR definition a material that makes up no more than 5 % of the packaging unit's mass does not make it composite. Composite paper packaging is assessed for recyclability in its own category, and the 5 % line also underlies the Commission's reading of the Annex V bans.
See: PPWR recyclability grades; barrier coatings for paper packaging
Contact-sensitive packaging (EU; PPWR)
Contact-sensitive packaging is the PPWR's term for packaging intended for products where contact with the packaging is safety-relevant, chiefly food under the food-contact rules, medicinal products and medical devices. It matters mainly for plastic recycled content: from 1 January 2030 (or three years after the implementing act on calculation and verification if that is later) contact-sensitive PET packaging other than single-use plastic beverage bottles must contain at least 30 % and contact-sensitive non-PET plastic packaging at least 10 % recycled content, lower targets than for other plastic packaging because food-grade recyclate is scarcer.
See: PPWR explained
Design for recycling (DfR; EU; PPWR Article 6)
Design for recycling is the set of criteria against which a packaging unit's recyclability is assessed, covering materials, coatings, inks, adhesives, labels, closures and how easily components separate. Under PPWR Article 6 the Commission must adopt design-for-recycling criteria per packaging category by 1 January 2028; they produce the percentage that sets the A, B or C grade. Until then, the Commission says the old Packaging Directive requirements and standards such as EN 13430 remain the reference.
See: PPWR recyclability grades
E-commerce packaging (EU; PPWR)
E-commerce packaging is transport packaging used to deliver products to the end user in the context of online sales, such as mailer boxes and shipping bags. Unlike other transport packaging it must carry the harmonised sorting label once that applies, and it falls under the 50 % empty space limit from 1 January 2030 or three years after the methodology act, whichever is later.
See: e-commerce packaging and the PPWR
Empty space ratio (EU; PPWR Article 24)
The empty space ratio is the share of a pack's volume not occupied by the product. Under PPWR Article 24, the economic operator that fills grouped, transport or e-commerce packaging must keep it at no more than 50 % from 1 January 2030 or three years after the Commission's calculation methodology act, whichever is later. Void fill such as paper cuttings, air cushions or foam chips counts as empty space, and sales packaging must keep empty space to the minimum from 12 February 2028.
See: e-commerce packaging and the PPWR
Grouped packaging (EU; PPWR; DE: Umverpackung; NL: verzamelverpakking)
Grouped packaging is packaging conceived to group a number of sales units at the point of sale, whether sold to the end user as such or used to fill shelves, and which can be removed without affecting the product. A printed shelf-ready tray or a multipack sleeve is grouped packaging, and it falls within the PPWR empty space limit from 2030.
See: PPWR explained
Harmonised sorting label (EU; PPWR Article 12)
The harmonised sorting label is the EU-wide pictogram label showing a packaging's material composition so consumers know how to sort it, with matching labels on waste bins. It applies from 12 August 2028 or 24 months after the Commission's implementing act enters into force, whichever is later; the act was due by 12 August 2026 but had not been adopted as of October 2026, so in practice it will apply later. Transport packaging other than e-commerce packaging and deposit-return packaging are excluded, and compostable packaging must state that it is not suitable for home composting.
See: PPWR labelling requirements
Heavy metals limit (EU; PPWR Article 5(4))
The PPWR limits the sum of lead, cadmium, mercury and hexavalent chromium in packaging and packaging components to 100 mg/kg. The limit carries over from the Packaging Directive and applies to inks, pigments and coatings as well as the base material, so a statement or test result against it belongs in the technical documentation.
See: PPWR Declaration of Conformity
HORECA sector (EU; hotels, restaurants, cafés)
HORECA is the hotel, restaurant and café sector; in the PPWR it means businesses in the accommodation and food service activities defined in the EU NACE classification. The term defines who must meet the takeaway reuse duties of Articles 32 and 33 and which premises the Annex V single-use plastic restrictions for dine-in food and drink apply to from 2030.
See: PPWR explained
Material identification codes (EU; Decision 97/129/EC; PAP codes)
Commission Decision 97/129/EC sets the numbers and abbreviations used to identify packaging materials, such as PAP 20 for corrugated board, PAP 21 for other board and PAP 22 for paper, often printed inside a recycling loop. According to the Commission's PPWR guidance the decision applies until 12 August 2028 and the abbreviations will no longer be allowed after that, as the harmonised sorting label takes over.
See: PPWR labelling requirements
Minimisation (EU; PPWR Article 10)
Packaging minimisation is the PPWR requirement, from 1 January 2030, that packaging weight and volume be reduced to the minimum needed for its function, such as protection, hygiene, stacking or required information. Article 10 also bans features meant only to increase perceived volume, including double walls, false bottoms and unnecessary layers, with limited exceptions for designs protected before 11 February 2025. The reasoning behind each pack's weight and size belongs in the technical documentation.
See: PPWR explained; e-commerce packaging and the PPWR
Recyclability performance grade (EU; PPWR Article 6; grades A, B, C)
A recyclability performance grade is the class, A, B or C, that a packaging unit receives from a design-for-recycling assessment: grade A at least 95 %, B at least 80 % and C at least 70 %, with anything below 70 % technically non-recyclable. From 1 January 2030, or 24 months after the delegated acts if later, only grades A to C may be placed on the EU market, and from 1 January 2038 only A or B. EPR fees will be modulated by grade; references to grades D and E come from the 2022 draft, not the adopted text.
See: PPWR recyclability grades
Recycled at scale (EU; PPWR Article 6)
Recycled at scale is the second PPWR recyclability test, which looks at whether a packaging type is actually collected, sorted and recycled in sufficient volume across the EU, not only designed for it. It applies from 1 January 2035, or five years after the Commission's methodology act if later, on top of the design-for-recycling grade; the thresholds per category had not been set as of October 2026.
See: PPWR recyclability grades
Recycled content targets (EU; PPWR Article 7)
From 1 January 2030, or three years after the implementing act on calculation and verification if that is later, plastic parts of packaging must contain minimum recycled content: 30 % for contact-sensitive PET, 10 % for contact-sensitive packaging of other plastics, 30 % for single-use plastic beverage bottles and 35 % for other plastic packaging, rising to 50, 25, 65 and 65 % in 2040. The targets apply to plastic bags, pouches, lids and windows, not to paper and board.
See: PPWR explained; recyclable mono-material pouches
Refill (EU; PPWR)
Refill is an operation in which an end user fills its own container, or a container provided at the point of sale, with a product offered by the seller. The PPWR's bring-your-own duty for takeaway outlets from 12 February 2027 is a refill obligation: customers must be able to have food or drink served in their own container at no higher price.
See: PPWR explained
Re-use system (EU; PPWR)
A re-use system is the set of organisational, technical or financial arrangements that lets reusable packaging complete repeated rotations, typically with deposits, collection, washing and return logistics. Closed-loop systems are run by a system operator; open-loop systems let packaging circulate among unspecified businesses. A takeaway cup is only reusable in practice if a re-use system for it exists.
See: PPWR labelling requirements
Reusable offer and bring-your-own duties (EU; PPWR Articles 32 and 33)
PPWR Article 32 requires HORECA final distributors selling takeaway food or drinks to let customers use their own containers at no higher price from 12 February 2027. Article 33 requires them to offer a reusable packaging option at no higher price from 12 February 2028 and, from 2030, to endeavour to sell 10 % of products in reusable formats. Micro-enterprises are exempt from this second duty only, not from the bring-your-own duty. Whether bread and pastries sold by the piece are covered has not been confirmed in official guidance.
See: PPWR explained
Reusable packaging (EU; PPWR; DE: Mehrwegverpackung; NL: herbruikbare verpakking)
Reusable packaging is packaging conceived, designed and placed on the market to be refilled or reused for the same purpose over multiple rotations within a re-use system. Under the PPWR its documentation is kept for 10 years rather than 5, and it will carry a reusable label with a QR code or other data carrier from 12 February 2029 or 30 months after the implementing act, whichever is later. Transport packaging has a 40 % reuse target by 2030, with cardboard boxes exempt.
See: PPWR labelling requirements
Sales packaging (EU; PPWR; DE: Verkaufsverpackung; NL: verkoopverpakking)
Sales packaging, also called primary packaging, is packaging conceived to form a sales unit of product and packaging for the end user at the point of sale, such as a printed carton or a pouch. Under the PPWR its empty space must be kept to the minimum from 12 February 2028, and it carries the harmonised sorting label once that applies.
See: PPWR explained
Service packaging (EU; DE: Serviceverpackung; NL: verkooppuntverpakking)
Service packaging is packaging filled at the point of sale to hand food or goods to the end user, such as takeaway bags, cups, wraps, burger boxes and pizza boxes. It is sales packaging, so it falls under EPR, and under the PPWR the business whose name or trademark is printed on it is normally the manufacturer. National producer rules for service packaging changed on 12 August 2026; in Germany the buyer of branded service packaging is now producer and manufacturer and pre-licensing survives only in narrow cases.
See: packaging compliance in Germany and Austria; packaging compliance in the Netherlands
Takeaway packaging (EU; PPWR; UK: food-to-go packaging; US: takeout packaging)
In the PPWR, take-away packaging is service packaging filled at attended points of sale with beverages or ready-prepared food packaged for transport and immediate consumption elsewhere without further preparation, and typically consumed from the packaging. Cups, clamshells, food boxes and containers usually fit the definition. It is the category the Article 32 and 33 bring-your-own and reusable-offer duties apply to.
See: PPWR explained; restaurant chain packaging
Transport packaging (EU; PPWR; DE: Transportverpackung; NL: transportverpakking)
Transport packaging, also called tertiary packaging, is packaging conceived to make handling and transport of sales units or grouped packaging easier and prevent damage, such as outer shipping cases, pallet wrap and corner boards; shipping containers themselves are excluded. It is exempt from the harmonised sorting label unless it is e-commerce packaging, falls under the empty space limit from 2030 and has a 40 % reuse target by 2030, with cardboard boxes exempt.
See: PPWR explained
Single-use plastics and earlier EU instruments
The SUP Directive still runs alongside the PPWR, and the old Packaging Directive explains where many current rules came from. Cup-specific rules are in paper cup rules in Europe and the UK.
Oxo-degradable plastic
Oxo-degradable plastic contains additives that make it fragment into small pieces through oxidation, without proven full biodegradation. It has been banned in the EU under the Single-Use Plastics Directive (EU) 2019/904 since 3 July 2021, so bags or films marketed as "oxo-biodegradable" cannot be supplied for EU orders.
See: recyclable, compostable and biodegradable claims
Packaging Directive (EU; Directive 94/62/EC, repealed)
Directive 94/62/EC on packaging and packaging waste was the EU's packaging law from 1994 until the PPWR replaced it, with the PPWR applying generally from 12 August 2026. It set the essential requirements, the heavy-metals limit and recycling targets that member states transposed nationally, supported by the EN 13427 to EN 13432 series of standards. Until the PPWR design-for-recycling acts are adopted, the Commission treats its recyclability requirements and standards such as EN 13430 as the reference.
See: PPWR explained
Plastic (legal definition; EU SUP Directive and PPWR)
Both the SUP Directive and the PPWR define plastic as a material consisting of a polymer, to which additives may have been added, that can function as a main structural component, excluding natural polymers that have not been chemically modified. The PPWR defines "plastic" but not "plastic packaging". Under the SUP Directive, paints, inks and adhesives are excluded, but a plastic coating or lining on paper makes the item a single-use plastic product.
See: barrier coatings for paper packaging
Single-use plastic product (EU; SUP Directive; Commission guidelines 2021/C 216/01)
A single-use plastic product under Directive (EU) 2019/904 is an item made wholly or partly of plastic that is not conceived for multiple trips. Commission guidelines 2021/C 216/01, updated by Notice C/2026/4813 of 8 September 2026 for caps and lids only, treat paper or board with a plastic coating or lining applied against water or grease as in scope, with no de minimis threshold; bio-based and compostable plastic linings such as PLA are also in scope. The guidelines do not mention water-based dispersion coatings by name, so their status depends on whether the coating polymer meets the plastic definition.
See: paper cup linings; barrier coatings for paper packaging
SUP Directive (EU; Directive (EU) 2019/904, Single-Use Plastics Directive)
The Single-Use Plastics Directive (EU) 2019/904 has banned plastic cutlery, plates, straws, stirrers, balloon sticks, cotton buds, expanded polystyrene food and drink containers and cups, and oxo-degradable plastics in the EU since 3 July 2021. It also sets marking requirements and EPR, including litter clean-up costs, for food containers, packets and wrappers, beverage cups and lightweight carrier bags. National implementations, such as the Dutch cup and container rules and Germany's single-use plastic fund, build on it.
See: paper cup rules in Europe and the UK
SUP marking (EU; "Plastic in product"; Implementing Regulation (EU) 2020/2151)
SUP marking is the printed label required by Commission Implementing Regulation (EU) 2020/2151 on beverage cups, including PE-lined and PLA-lined paper cups, and certain other single-use plastic products. It combines a prescribed pictogram with the words "Plastic in product" ("MADE OF PLASTIC" on cups made wholly of plastic) in the language of the market where the cup is sold, and is a separate obligation from the PPWR sorting label.
See: paper cup rules in Europe and the UK; packaging artwork preparation
Food contact and chemical safety
Rules for materials that touch food and for substances in packaging. The full picture is in food-contact packaging compliance in the EU, UK and US and PFAS-free food packaging.
BfR Recommendation XXXVI (DE; paper and board for food contact)
BfR Recommendation XXXVI is the German Federal Institute for Risk Assessment's recommendation for paper and board intended for food contact. Because there is no harmonised EU measure for paper and board, it serves as the de facto benchmark across the EU and in the UK, and buyers commonly expect a Declaration of Compliance referencing it alongside Regulation (EC) 1935/2004. It is a recommendation, not a law.
See: food-contact packaging compliance
BPA Regulation (EU; Regulation (EU) 2024/3190)
Regulation (EU) 2024/3190 restricts bisphenol A (BPA) and other hazardous bisphenols in food-contact materials. It entered into force on 20 January 2025 and its main transition period ended on 20 July 2026. It covers coatings, varnishes, printing inks and adhesives used in food-contact materials, not the paper itself, so buyers ask for confirmation that inks, varnishes and adhesives are not made with BPA.
See: food-contact packaging compliance
Declaration of Compliance (DoC; food contact; DE: Konformitätserklärung)
A Declaration of Compliance (DoC) is the written statement a supplier provides confirming that a food-contact material meets the applicable rules for stated conditions of use: food types, temperature, contact time and surface-to-volume ratio. It is legally required for plastics under Regulation (EU) 10/2011 at each marketing stage other than retail, with content set in Annex IV, and is expected by buyers for paper and board. It is not the same document as the PPWR EU Declaration of Conformity.
See: food-contact packaging compliance
Druckfarbenverordnung (DE; German Printing Ink Ordinance)
The Druckfarbenverordnung is Germany's printing ink ordinance, introduced as the 21st amendment of the Bedarfsgegenständeverordnung, which sets a positive list of substances for inks used on food-contact materials. After an extension approved in December 2025, the ink rules apply from 1 January 2027, with the transition period ending on 31 December 2026. It is German law, but it is becoming the ink reference for packaging sold across the EU.
See: food-contact packaging compliance; printing on greaseproof paper
EuPIA (European Printing Ink Association)
EuPIA is the European Printing Ink Association, whose guidance on inks for food-contact materials, including its exclusion policy and good manufacturing practice guideline, is an established market reference for low-migration inks. Ink makers commonly confirm conformity with EuPIA guidance in the statements that support a converter's Declaration of Compliance.
See: food-contact packaging compliance
Food contact material (FCM; DE: Lebensmittelkontaktmaterial; NL: voedselcontactmateriaal)
A food contact material (FCM) is any material or article intended to come into contact with food, including packaging, wraps, cups and the inks and coatings on them. In the EU, Framework Regulation (EC) 1935/2004 requires FCMs not to transfer constituents to food in quantities that could endanger health or change the food unacceptably, and sets labelling and traceability duties. GB applies the assimilated version of the same rules, and Northern Ireland follows EU rules.
See: food-contact packaging compliance
Framework Regulation (EU; Regulation (EC) 1935/2004)
Regulation (EC) 1935/2004 is the EU framework for all food-contact materials. Article 3 requires that materials do not transfer constituents to food in quantities that could endanger health, change its composition unacceptably or affect taste and odour; Article 15 covers labelling, including the "for food contact" wording or glass-and-fork symbol; and Article 17 requires traceability at all stages, which in practice means lot coding back to board, ink and coating batches.
See: food-contact packaging compliance
Functional barrier
A functional barrier is a layer within a food-contact material that prevents substances behind it, such as mineral oil from recycled fibre or unlisted substances in an outer layer, from migrating into food above applicable limits. Where compliance relies on a functional barrier, the Declaration of Compliance should say so and the barrier's performance should be supported by testing for the intended contact time and temperature.
See: mineral oil barriers and food-safe cartons
GMP Regulation (EU; Regulation (EC) 2023/2006)
Regulation (EC) 2023/2006 sets good manufacturing practice (GMP) for food-contact materials, requiring a documented quality assurance and quality control system at each production stage. It also requires that printing inks on the non-food-contact side do not transfer to the food-contact side through the substrate or by set-off in the stack or reel, which makes ink selection, drying and stacking a compliance topic.
See: food-contact packaging compliance
MOSH and MOAH (mineral oil hydrocarbons)
MOSH (mineral oil saturated hydrocarbons) and MOAH (mineral oil aromatic hydrocarbons) are the two main fractions of mineral oil that can migrate from packaging into food, mainly from recycled fibre and mineral-oil-based inks. There is no binding EU limit for packaging as of October 2026; virgin fibre, functional barriers and mineral-oil-free inks are the usual mitigations.
See: mineral oil barriers and food-safe cartons
NIAS (non-intentionally added substances)
NIAS are substances present in a food-contact material that were not added on purpose, such as impurities in raw materials, reaction and breakdown products, or contaminants from recycled input. Regulation (EU) 10/2011 requires them to be covered by the manufacturer's risk assessment for plastics, and buyers increasingly ask how NIAS were assessed for coatings, inks and adhesives as well.
See: food-contact packaging compliance
Overall migration limit (OML)
The overall migration limit (OML) is the maximum total amount of substances a plastic food-contact material may release into food or a food simulant, set at 10 mg/dm² under Regulation (EU) 10/2011. It is verified by migration testing under time and temperature conditions that represent the intended use, and the test conditions should match those stated on the Declaration of Compliance.
See: food-contact packaging compliance
PFAS (per- and polyfluoroalkyl substances; EU PPWR Article 5(5))
PFAS are a large group of fluorinated chemicals historically used to grease-proof paper and board. Under PPWR Article 5(5), food-contact packaging may not be placed on the EU market from 12 August 2026 at or above 25 ppb for any single PFAS or 250 ppb for the sum of PFAS (targeted analysis), or 50 ppm for all PFAS including polymeric PFAS. Total fluorine above 50 mg/kg is not itself a limit: it obliges the supplier to prove, on request, whether the fluorine comes from PFAS or from non-PFAS substances. In the US, the FDA and many states have ended PFAS grease-proofing in food packaging; GB had no PFAS restriction for food packaging as of October 2026.
Plastics Regulation (EU; Regulation (EU) 10/2011)
Regulation (EU) 10/2011 governs plastic food-contact materials and plastic layers in multi-material structures, such as PE coatings on cups and containers, plastic windows on bakery bags, and plastic bags and pouches. It sets a positive list of authorised substances, an overall migration limit of 10 mg/dm², specific migration limits and a Declaration of Compliance requirement at each marketing stage other than retail.
See: food-contact packaging compliance
REACH (EU; Regulation (EC) 1907/2006)
REACH is the EU regulation on the registration, evaluation, authorisation and restriction of chemicals, Regulation (EC) 1907/2006. It applies to substances in inks, coatings and adhesives used to make packaging and supplies the polymer definition that the PPWR's definition of plastic refers to. Under PPWR Article 5(5), the REACH manufacturer, importer or downstream user of a material must provide proof of the fluorine source when total fluorine in food-contact packaging exceeds 50 mg/kg.
Recycled plastics Regulation (EU; Regulation (EU) 2022/1616)
Commission Regulation (EU) 2022/1616 of 15 September 2022 governs recycled plastic materials and articles intended for food contact and repealed Regulation (EC) No 282/2008. Recycled plastic for food contact must come from recycling processes and technologies that comply with it, so a pouch or bag claiming food-contact recycled content needs the supplier's documentation under this regulation.
See: food-contact packaging compliance; LDPE vs HDPE vs recycled PE bags
Specific migration limit (SML)
A specific migration limit (SML) caps the amount of an individual listed substance that may migrate from a plastic food-contact material into food, expressed in mg per kg of food. SMLs are set in the Union list of Regulation (EU) 10/2011, and the Declaration of Compliance should name substances with SMLs or other restrictions and confirm testing under the relevant conditions.
See: food-contact packaging compliance
SVHC (substance of very high concern; REACH Candidate List)
A substance of very high concern (SVHC) is a chemical identified under REACH as carcinogenic, mutagenic, toxic for reproduction, persistent and bioaccumulative, or of equivalent concern, and placed on the Candidate List. A supplier of an article containing a Candidate List substance above 0.1 % by weight must give recipients enough information for safe use, so buyers often ask for an SVHC statement alongside food-contact documents.
See: food-contact packaging compliance
Swiss Ordinance (CH; SR 817.023.21, Annex 10)
The Swiss Ordinance on materials and articles in contact with food, SR 817.023.21, contains in Annex 10 a list of substances permitted in packaging inks. Although it is Swiss law, it has long been used across Europe as a market reference for low-migration inks, alongside EuPIA guidance and, from 1 January 2027, the German Printing Ink Ordinance.
See: food-contact packaging compliance
Total fluorine (TF; total organic fluorine, TOF)
Total fluorine is a screening measurement of all fluorine in a material, including polymeric PFAS that targeted methods miss, usually by combustion ion chromatography. Under the PPWR, total fluorine above 50 mg/kg is not a limit but triggers the duty to prove whether the fluorine comes from PFAS or from non-PFAS substances, and Commission guidance treats a result below 50 mg/kg as indicating compliance. US states and the BPI compostability certification commonly use 100 ppm total organic fluorine as a threshold.
Sustainability terms and green claims
What environmental terms mean technically and what the claim rules in the EU, UK and US require. Claim wording by market is covered in recyclable, compostable and biodegradable packaging.
Bio-based (bio-based content)
Bio-based describes material made wholly or partly from biomass, such as sugarcane-derived bio-PE or PLA from plant starch, rather than fossil resources; the share is usually measured by radiocarbon analysis. Bio-based says nothing about end of life: bio-PE is chemically identical to fossil PE and is not biodegradable. Under the PPWR a bio-based content label is voluntary but must follow a harmonised format once the implementing act exists.
See: recyclable, compostable and biodegradable claims
Biodegradable (DE: biologisch abbaubar; NL: biologisch afbreekbaar)
Biodegradable means broken down by micro-organisms at some point in some environment, so without a stated environment and time frame the word gives a buyer no usable information. Directive (EU) 2024/825 names it as an example of a generic claim banned from 27 September 2026 unless strict conditions are met, and the UK CMA and US FTC treat unqualified biodegradable claims as misleading.
See: recyclable, compostable and biodegradable claims
Carbon footprint (product carbon footprint, PCF)
A product carbon footprint is the total greenhouse gas emissions attributed to a product over defined life-cycle stages, expressed in kg CO2 equivalent per unit or per tonne; ISO 14067 is the main standard. Results depend heavily on system boundaries (cradle-to-gate or cradle-to-grave), data sources and allocation rules, so two footprints are only comparable when calculated the same way. In the EU, claims that a product is "climate neutral" based on offsetting are banned from 27 September 2026.
See: recyclable, compostable and biodegradable claims
Chain of custody (CoC)
Chain of custody (CoC) is the certified tracking of forest-based material through every company that takes legal ownership of it, from forest to finished product, under schemes such as FSC and PEFC. Each owner in the chain needs its own CoC certificate before an on-product label can be used, and writing "made from FSC paper" without that chain is still treated as using the mark.
See: recyclable, compostable and biodegradable claims
Compostable (industrially compostable; DE: kompostierbar; NL: composteerbaar)
Industrially compostable packaging breaks down into water, carbon dioxide and biomass in managed industrial composting at higher, controlled temperatures within a defined time, shown by certification to EN 13432 in the EU or ASTM D6400 or D6868 in the US. Under PPWR Article 9, only tea and coffee bags and pods, sticky fruit and vegetable labels and, where a Member State chooses, very lightweight and lightweight plastic carrier bags must be compostable; all other packaging, compostable or not, must be recyclable.
See: recyclable, compostable and biodegradable claims
Empowering Consumers Directive (EU; Directive (EU) 2024/825)
Directive (EU) 2024/825, on empowering consumers for the green transition, applies in EU Member States from 27 September 2026 through national consumer law. It bans generic environmental claims such as "eco-friendly", "green" or "biodegradable" without recognised excellent environmental performance, requires sustainability labels to be based on a certification scheme or set by public authorities, and bans offset-based "climate neutral" product claims.
See: recyclable, compostable and biodegradable claims
EN 13432
EN 13432 is the European standard for industrially compostable packaging, setting requirements for disintegration, biodegradation, ecotoxicity and limits on certain substances. It is assessed on the finished construction, including inks, adhesives and coatings, so a certificate for a base paper or coating does not automatically cover a printed item. It does not cover home composting.
See: recyclable, compostable and biodegradable claims
FSC (Forest Stewardship Council)
FSC is an international forest certification scheme whose on-product labels, FSC 100%, FSC Mix and FSC Recycled, show that fibre comes from certified, controlled or recycled sources. Using the label requires chain-of-custody certification for each company that takes ownership of the material, plus a trademark licence and label approval; it is a voluntary label system, not a legal requirement.
See: recyclable, compostable and biodegradable claims
Generic environmental claim (EU)
A generic environmental claim is a broad statement of environmental benefit, such as "eco", "green", "planet-friendly" or an unexplained leaf symbol, that is not specified on the same medium. Under Directive (EU) 2024/825 such claims are banned from 27 September 2026 unless the trader can show recognised excellent environmental performance relevant to the claim, and self-created labels that look like certification marks are effectively prohibited.
See: recyclable, compostable and biodegradable claims
Green Claims Directive (EU; proposal)
The Green Claims Directive is a European Commission proposal that would add prior substantiation and verification requirements for explicit environmental claims. It has been on hold since June 2025, so as of October 2026 the binding EU rules on packaging claims come from Directive (EU) 2024/825 and national consumer law.
See: recyclable, compostable and biodegradable claims
Home compostable (OK compost HOME; EN 17427)
Home compostable packaging is certified to break down in a garden compost heap at ambient temperature, usually through private certification such as OK compost HOME. There is no harmonised EU home-compost standard for packaging generally; EN 17427 covers home-compostable carrier bags only. An industrial compostability certificate does not support a home compostable claim.
See: recyclable, compostable and biodegradable claims
Life cycle assessment (LCA; DE: Ökobilanz)
A life cycle assessment (LCA) quantifies the environmental impacts of a product across its life cycle, from raw material extraction through manufacture, transport and use to end of life, using the method in ISO 14040 and ISO 14044. It covers several impact categories, such as climate change, water use and resource depletion, not only carbon. Comparative LCA claims between packaging options need consistent functional units and boundaries and, for public use, critical review.
See: recyclable, compostable and biodegradable claims
Mono-material packaging
Mono-material packaging is made of one material family, such as all-PE or all-PP flexible film or paper with only a thin compatible coating, so it can be recycled in a single stream. It is an industry term rather than a legal category, but mono-material design usually scores better under PPWR design-for-recycling criteria and UK RAM than multi-material laminates such as PET/PE or foil structures.
See: recyclable mono-material pouches
PEFC (Programme for the Endorsement of Forest Certification)
PEFC is an international umbrella forest certification system that endorses national schemes. As with FSC, using a PEFC label on packaging requires chain-of-custody certification through the supply chain and approved trademark use; it is a voluntary label system.
See: recyclable, compostable and biodegradable claims
Post-consumer recycled content (PCR; US paper: PCW, post-consumer waste)
Post-consumer recycled (PCR) content is material recovered from products that have been used by consumers or businesses and discarded, then reprocessed, such as used film or old corrugated boxes; US paper bag laws call it post-consumer waste (PCW) content. It is the share most recycled-content rules count: California SB 1053 requires 50 % post-consumer content in recycled paper carryout bags from 1 January 2028, and the UK Plastic Packaging Tax will accept only post-consumer plastic from 1 April 2027.
See: paper bag regulations by market; LDPE vs HDPE vs recycled PE bags
Pre-consumer recycled content (PIR, post-industrial recycled)
Pre-consumer or post-industrial recycled (PIR) content is material diverted from a manufacturing process, such as converter trim or off-spec film, and reprocessed. Scrap reintroduced into the same process after only shredding or grinding is generally not counted as recycled. From 1 April 2027 the UK Plastic Packaging Tax no longer accepts pre-consumer plastic as recycled content, so specifications relying on PIR to reach 30 % need post-consumer content.
See: LDPE vs HDPE vs recycled PE bags; UK packaging regulations
Recyclable (DE: recyclingfähig; NL: recyclebaar)
A recyclable claim means the packaging can be collected, sorted and reprocessed in existing streams at scale in the market where it is sold. Under the PPWR, EU packaging must reach recyclability grade A, B or C from 1 January 2030 at the earliest; in the US an unqualified claim requires recycling facilities available to at least 60 % of consumers under the FTC Green Guides, and California SB 343 adds stricter criteria whose enforcement is currently enjoined.
See: recyclable, compostable and biodegradable claims
Recycled content
Recycled content is the share of a pack's material that comes from recycled sources, normally stated as a percentage by weight and split into pre-consumer and post-consumer content. It is regulated through the PPWR plastic targets from 2030, the UK Plastic Packaging Tax 30 % threshold, California SB 1053 and the New Jersey Recycled Content Law for paper bags; New York's state bag law sets no minimum. Claims need supplier documentation or chain-of-custody records for the stated percentage.
See: PPWR explained; paper bag regulations by market
Repulpability
Repulpability is the ability of paper or board to be broken down in water at a paper mill so its fibres can be recovered, with coatings, films and adhesives screened out as rejects. It is assessed by laboratory methods such as the Cepi harmonised test method or PTS-RH 021, and lower polymer weight, as with dispersion barriers, generally improves results compared with PE coating. Repulpability evidence is a central recyclability input for coated paper packaging in current assessments and is expected to feature in the PPWR design-for-recycling criteria.
See: barrier coatings for paper packaging; is greaseproof paper recyclable or compostable?
Germany, Austria and the Netherlands
National EPR and reuse terms in the three EU markets closest to most foodservice chains. Details are in packaging compliance in Germany and Austria and packaging compliance in the Netherlands.
Afvalbeheersbijdrage verpakkingen (NL; packaging waste management fee)
The afvalbeheersbijdrage is the Dutch per-kilogram packaging waste management fee that producers pay to Verpact to fund collection, sorting and recycling. Producers placing more than 50,000 kg of packaging on the Dutch market per year declare all of it, with the value of 50,000 kg deducted; single-use plastic products count from the first unit and attract a surcharge per 1,000 plastic-containing items. The 2026 rate for paper and board is EUR 0.017 per kg, unchanged for 2027.
See: packaging compliance in the Netherlands
ARA (AT; Altstoff Recycling Austria)
ARA is one of the Austrian collection and recovery systems (Sammel- und Verwertungssysteme) through which packaging placed on the Austrian market is licensed under the Verpackungsverordnung 2014; Reclay is another. The Austrian brand owner, importer or, for service packaging, the Austrian manufacturer or importer of the packaging usually holds the licence. National implementation of the PPWR's EPR side was pending as of October 2026.
See: packaging compliance in Germany and Austria
Bevollmächtigter (DE/AT; authorised representative)
A Bevollmächtigter is an authorised representative established in Germany or Austria who fulfils packaging EPR duties for a company without an establishment there. In Germany, § 5 VerpackDG requires foreign producers supplying packaging directly to end users to appoint one before first supply; in Austria, foreign distance sellers to private consumers have had to appoint one since 1 January 2023 (§ 16b Verpackungsverordnung), while the voluntary option of § 16a is open only to suppliers established in another EU Member State.
See: packaging compliance in Germany and Austria
DIVID (DE; Einwegkunststofffonds platform)
DIVID is the Umweltbundesamt's online platform for Germany's single-use plastic fund. Producers of levy-relevant single-use plastic products, usually the first party placing them on the German market, have had to register on DIVID since 1 January 2024 and report quantities each year by 15 May.
See: packaging compliance in Germany and Austria
Dual system (DE: duales System; Systembeteiligung)
A dual system is a licensed German take-back scheme in which producers must participate (Systembeteiligung) and pay licence fees, before placing on the market packaging that ends up with private end consumers. Participation is separate from, and additional to, registration in LUCID, and continues under the VerpackDG.
See: packaging compliance in Germany and Austria
Einwegkunststofffonds (DE; single-use plastic fund; EWKFondsG)
The Einwegkunststofffondsgesetz is Germany's single-use plastic fund law: producers of certain single-use plastic products register on DIVID and pay an annual levy per kilogram, first charged in 2025 on 2024 quantities, for example EUR 0.177 per kg for food containers and EUR 1.236 for beverage cups. The levy is charged on the whole product's weight, so a PE-lined paper cup is levied including its paper, and since 3 November 2025 food containers and wrappers holding more than 500 g of food are out of scope.
See: packaging compliance in Germany and Austria
LUCID (DE; Verpackungsregister)
LUCID is Germany's packaging register, run by the Zentrale Stelle Verpackungsregister (ZSVR). Registration is mandatory, cannot be delegated and must be in place before system-relevant packaging is placed on the German market; it continues under the VerpackDG, and a restaurant or chain that is the producer of its branded service packaging registers itself.
See: packaging compliance in Germany and Austria
Mehrwegangebotspflicht (DE; reusable offer obligation; Mehrwegpflicht)
The Mehrwegangebotspflicht has required German takeaway outlets since 1 January 2023 to offer a reusable alternative at no higher price when they fill single-use plastic food packaging or single-use cups of any material; it is now § 60 VerpackDG. Under § 61, businesses with no more than five employees in total and 80 m² of sales area may instead fill customers' own containers; staff are counted company-wide, so chain branches generally do not qualify.
See: packaging compliance in Germany and Austria
Netherlands single-use cup and container rules (NL; wegwerpbekers en -bakjes)
Since 1 January 2024 the Netherlands has banned single-use cups and food containers containing plastic, including PE-lined paper cups, for on-site consumption, apart from a narrow collection-based exception enforced by the ILT. For takeaway since 1 July 2023, outlets must offer a reusable option or accept customers' own containers, and that duty continues; the to-go surcharge is due to be abolished from 1 January 2027, but the amending regulation was not yet published as of October 2026.
See: packaging compliance in the Netherlands; paper cup rules in Europe and the UK
Pre-licensing (DE: Vorlizenzierung; Vorvertreiber)
Pre-licensing is the German practice in which an upstream supplier, the Vorvertreiber, takes over dual-system participation for unfilled service packaging it supplies. Since 12 August 2026, § 7(2) VerpackDG allows it only in two narrow cases where neutral packaging bought from abroad is branded or modified afterwards; it is not available for packaging ordered with the buyer's name, logo or brand, so a foreign manufacturer cannot pre-license a German chain's branded packaging. The original producer must still register in LUCID.
See: packaging compliance in Germany and Austria
VerpackDG (DE; Verpackungsrecht-Durchführungsgesetz; formerly VerpackG)
The VerpackDG replaced the German Packaging Act (Verpackungsgesetz, VerpackG) from 12 August 2026, published in BGBl. 2026 I Nr. 207, and organises German EPR around the directly applicable PPWR. LUCID registration, dual-system participation, the reusable-offer duty (§ 60) and the lightweight plastic carrier bag ban (§ 12(1)) continue under it, with new producer rules for service packaging.
See: packaging compliance in Germany and Austria
Verpact (NL; Stichting Afvalfonds Verpakkingen)
Verpact is the Dutch producer responsibility organisation for packaging, formerly called Afvalfonds Verpakkingen. It collects the waste management fee from producers, whose obligation is made compulsory by a generally binding declaration of the industry agreement for 2023 to 2027, and since 12 August 2026 it applies the PPWR producer definition. Annual declarations are due before 1 April and records are kept for seven years.
See: packaging compliance in the Netherlands
Verpackungsverordnung 2014 (AT; VVO)
The Verpackungsverordnung 2014, amended in 2023, is Austria's packaging ordinance, under which packaging is licensed through collection and recovery systems such as ARA or Reclay. It sets the Bevollmächtigter rules for foreign distance sellers, while the Abfallwirtschaftsgesetz (AWG 2002) places the primary obligation for service packaging on its Austrian manufacturer or importer and has banned plastic carrier bags since 1 January 2020.
See: packaging compliance in Germany and Austria
Vollständigkeitserklärung (DE; declaration of completeness)
The Vollständigkeitserklärung is the annual declaration of completeness, due by 15 May, in which German producers report the packaging they placed on the market in the previous year and how it was licensed; it is verified by a registered expert or auditor and filed with the ZSVR. Producers below the statutory thresholds of 80 t of glass, 50 t of paper and board and 30 t of other materials a year are exempt unless the ZSVR requests one. Under the VerpackDG the duty sits in § 10 and, in the narrow pre-licensing cases, passes to the Vorvertreiber together with registration and reporting duties.
See: packaging compliance in Germany and Austria
ZSVR (DE; Zentrale Stelle Verpackungsregister)
The ZSVR is the German central agency for the packaging register: it runs LUCID, checks that producers register and participate in a dual system, and publishes guidance on how the VerpackDG and PPWR roles apply, including its 2026 guidance on service packaging. Buyers unsure whether they or a supplier is the producer should check ZSVR guidance first.
United Kingdom
UK producer responsibility, tax and single-use rules, which differ by nation. The full guide is UK packaging regulations.
Assimilated food-contact law (GB) and the Windsor Framework (NI)
Great Britain kept the EU food-contact regulations, 1935/2004, 2023/2006 and 10/2011, as assimilated law, while Northern Ireland follows current EU rules under the Windsor Framework. The PPWR has also applied to packaging placed on the Northern Ireland market since 12 August 2026, except its reuse, EPR and deposit return provisions, so one stock supplying GB and NI is best specified to EU rules.
See: UK packaging regulations; food-contact packaging compliance
Carrier bag charge (UK)
UK carrier bag charges differ by nation. England has a 10p minimum charge only on single-use plastic carrier bags of 70 microns or less, with paper bags not charged; Scotland charges at least 10p and Wales at least 5p on single-use bags including paper, and Northern Ireland levies 25p on new carrier bags of any material retailing at £5 or less. Exemptions, for example for unwrapped food, also differ by nation.
See: paper bag regulations by market
DMCC Act 2024 (UK; Digital Markets, Competition and Consumers Act)
The Digital Markets, Competition and Consumers Act 2024 gave the Competition and Markets Authority power, from April 2025, to fine businesses directly for consumer law breaches, including misleading environmental claims, up to 10 % of global turnover without first going to court. It turned the Green Claims Code from guidance into a practical enforcement risk for printed packaging claims.
Fibre-based composite (FBC; UK pEPR)
Fibre-based composite is a separate material category in UK pEPR for packaging made mainly of paper or board with other materials bonded to it, such as PE-lined cups. Under RAM, a fibre-based item with more than 5 % plastic by mass is assessed as fibre-based composite rather than paper and board, and FBC carries higher fees per tonne than paper and card.
Green Claims Code (UK; CMA)
The Green Claims Code is the UK Competition and Markets Authority's guidance requiring environmental claims to be truthful and accurate, clear, complete, fair in comparisons, based on the full life cycle and substantiated. Since April 2025 the DMCC Act 2024 lets the CMA fine businesses directly, up to 10 % of global turnover, for breaches of consumer law.
See: UK packaging regulations; recyclable, compostable and biodegradable claims
OPRL (On-Pack Recycling Label; UK)
OPRL is the UK's voluntary on-pack recycling labelling scheme. Mandatory "Recycle" and "Do not recycle" labelling planned under pEPR has been removed from the regulations pending alignment, with no current date, so OPRL labelling remains voluntary and artwork should keep space for a future mandated mark.
PackUK (UK; pEPR scheme administrator)
PackUK is the scheme administrator for UK packaging EPR. It calculates fees per tonne for each material category from the cost of managing household packaging waste, issues notices of liability to large producers and pays local authorities. As of October 2026 it planned to issue confirmed year 2 (2026/27) fees with the initial notices of liability around the end of November 2026.
pEPR (UK; packaging extended producer responsibility)
pEPR is the UK's packaging EPR scheme. A UK-established business is an obligated producer if its turnover exceeds £1 million and it handles more than 25 tonnes of packaging a year, and large producers (over £2 million and 50 tonnes) pay waste management fees, invoiced from October 2025 and modulated by RAM rating from year 2 (2026/27). Activities include importing packaged goods and supplying unfilled packaging; a non-UK manufacturer is not the producer, the UK importer or brand owner is.
Plastic Packaging Tax (UK; PPT)
Plastic Packaging Tax is a UK tax on plastic packaging components containing less than 30 % recycled plastic, charged at £228.82 per tonne from 1 April 2026. A component counts as plastic if plastic is its heaviest material by weight, and manufacturers and importers of 10 tonnes or more of plastic packaging in 12 months, filled or unfilled, must register with HMRC. From 1 April 2027 pre-consumer plastic no longer counts as recycled content.
PRN and PERN (UK; packaging recovery notes)
A PRN (packaging waste recovery note) is evidence issued by an accredited UK reprocessor that a tonnage of packaging waste has been recycled; a PERN (packaging waste export recovery note) is the equivalent issued by an accredited exporter. Obligated producers buy them to show they have met their annual recycling obligations, a system that continues alongside the pEPR waste management fees, so PRN prices are a separate cost line from PackUK fees.
RAM (UK; recyclability assessment methodology; red, amber, green)
RAM is the methodology that rates UK household packaging green, amber or red for recyclability, used from year 2 of pEPR (2026/27) to modulate fees, with red paying the most for its material. PackUK's illustrative year 2 fees for paper and card were £190, £210 and £250 per tonne for green, amber and red; confirmed fees had not been published as of October 2026. RAM v1.1 covers the 2025 and 2026 reporting years and RAM 2027 applies from 1 January 2027; both rate greaseproof, siliconised and waxed paper red.
Simpler Recycling (England)
Simpler Recycling is England's reform of waste collection. Since 31 March 2025, businesses with 10 or more full-time-equivalent employees must separate recyclable waste for collection; plastic film collection, originally due by 31 March 2027, has been delayed to 2030 following a July 2026 Defra announcement. For restaurants it affects back-of-house waste streams.
Single-use plastics bans (UK: England, Scotland, Wales)
England has banned the supply of single-use plastic cutlery, balloon sticks, stirrers and polystyrene food and drink containers since 1 October 2023, and restricts plates, bowls and trays, including plastic-coated paper ones; plates, bowls and trays supplied to businesses, or that are packaging pre-filled or filled at the counter, are exempt. Scotland's ban has applied since 1 June 2022 and Wales's since 30 October 2023; neither covers bowls or trays, and Wales's second phase has been postponed.
United States
Federal food-contact law, state packaging laws and claim rules. The full guide is US foodservice packaging regulations.
21 CFR Parts 174-178 (US; FDA indirect food additive regulations)
21 CFR Parts 174 to 178 are the FDA regulations listing substances permitted in food-contact materials, the so-called indirect food additives: Part 175 covers adhesives and coating components, Part 176 paper and paperboard components, Part 177 polymers such as polyethylene, and Part 178 adjuvants and sanitisers. A food-contact substance needs a listing here, GRAS status, a prior sanction or an effective Food Contact Notification for its intended use.
See: food-contact packaging compliance
21 CFR 176.170 and 176.180 (US; paper and paperboard)
21 CFR 176.170 lists substances permitted as components of paper and paperboard in contact with aqueous and fatty foods, with extraction limits and conditions of use by food type and temperature; burger wraps, pizza boxes, cups and soup containers are typically assessed under it. 21 CFR 176.180 covers paper and paperboard in contact with dry food, such as bakery bags for dry goods.
See: US foodservice packaging regulations
ASTM D6400 and D6868 (US; compostability standards)
ASTM D6400 is the US specification for plastics designed to be composted in municipal or industrial facilities, and ASTM D6868 covers biodegradable plastic coatings or layers on paper and other compostable substrates, the one relevant to PLA- or dispersion-coated paper. Certification bodies such as BPI test against them, and California and other states tie compostable labelling to them.
See: recyclable, compostable and biodegradable claims
BPI (Biodegradable Products Institute; US)
BPI is the main North American certifier of compostable products and packaging, testing against ASTM D6400 and D6868. Since 1 January 2020 it has required no intentionally added fluorinated chemicals and no more than 100 ppm total organic fluorine, which links compostable certification to PFAS-free construction.
See: recyclable, compostable and biodegradable claims
California AB 1201 (US-CA; compostable labelling)
California AB 1201 sets rules for labelling products "compostable" or "home compostable". From 1 January 2026 such products must also be allowed inputs under the USDA National Organic Program; CalRecycle extended this to 30 June 2027 for products containing synthetic substances such as PLA or PHA that otherwise meet the rules, with any renewal capped at 1 January 2031, so the current position should be checked before printing.
See: US foodservice packaging regulations
California SB 54 (US-CA; packaging EPR)
California SB 54 is California's packaging EPR law, under which producers, typically brand owners, or the importer or distributor where the brand has no US presence, must join a producer responsibility organisation and finance the state's packaging programme. The Circular Action Alliance acts as PRO; recyclability claims are restricted separately by SB 343.
See: US foodservice packaging regulations
California SB 343 (US-CA; recyclability claims)
California SB 343 restricts use of the chasing-arrows symbol and "recyclable" claims on packaging that does not meet the state's recyclability criteria. Its restrictions were due to apply from 4 October 2026, but on 14 July 2026 a federal court preliminarily enjoined the state from enforcing it against any business while a constitutional challenge continues, so its status should be checked before printing.
See: US foodservice packaging regulations
California SB 1053 (US-CA; carryout bags)
California SB 1053 bans plastic carryout bags at covered stores, meaning larger grocery stores, large stores with a pharmacy and licensed convenience stores, food marts and liquor stores, from 1 January 2026; restaurants are not covered stores. Recycled paper carryout bags must be accepted in curbside recycling, carry the manufacturer's name, country of manufacture and post-consumer content percentage, be sold for at least 10 cents and contain at least 50 % post-consumer content from 1 January 2028, with no interim percentage for 2026 and 2027.
See: paper bag regulations by market
Circular Action Alliance (CAA; US)
The Circular Action Alliance is the producer responsibility organisation that acts for producers in most US states with packaging EPR laws, including Oregon, where the programme has operated since July 2025. Producers register and report through the CAA in each state where their packaging reaches consumers.
See: US foodservice packaging regulations
FDA (US Food and Drug Administration)
The FDA regulates food-contact materials in the US under the Federal Food, Drug, and Cosmetic Act. It does not approve, certify or register finished packaging or packaging factories; compliance is shown substance by substance against the CFR, GRAS status, prior sanctions or Food Contact Notifications, usually in a supplier's letter of guaranty. On 28 February 2024 it announced that PFAS grease-proofing agents are no longer sold for US food contact.
See: food-contact packaging compliance
Food Contact Notification (FCN; US)
A Food Contact Notification (FCN) is the FDA's premarket notification route for new food-contact substances. An effective FCN applies only to the notifier's substance as manufactured by it and to customers using that substance, not to similar substances from other makers, so a supplier citing an FCN should say whose notification it is. In January 2025 the FDA determined that 35 PFAS FCNs were no longer effective.
See: food-contact packaging compliance
FTC Green Guides (US; 16 CFR Part 260)
The FTC Green Guides (16 CFR Part 260, 2012) are the US Federal Trade Commission's guidance on environmental marketing claims, under review since December 2022 but still in force as of October 2026. An unqualified recyclable claim requires recycling facilities to be available to a substantial majority, 60 %, of consumers or communities where the item is sold; otherwise the claim must be qualified.
See: recyclable, compostable and biodegradable claims
GRAS (generally recognised as safe; US)
GRAS status means a substance is generally recognised by qualified experts as safe for its intended use, which exempts it from food additive approval under US law. A GRAS substance can be a legal basis for use in food-contact packaging, but only for the uses and conditions on which the GRAS determination rests.
See: food-contact packaging compliance
Letter of guaranty (US; FDA compliance statement)
A letter of guaranty is the US supplier's written statement that a food-contact material complies with the applicable FDA regulations, naming the finished product, its components, the CFR sections or other legal bases relied on, and the food types and temperatures covered. It is the US counterpart of the EU Declaration of Compliance, and importers typically need one from the manufacturer.
See: food-contact packaging compliance
New Jersey Recycled Content Law (US-NJ; paper carryout bags)
New Jersey's Recycled Content Law has required paper carryout bags sold in the state to contain at least 40 % post-consumer recycled content since 18 January 2024, or 20 % for bags made to hold 8 lb or less, with the obligation on the bag manufacturer. It is separate from New Jersey's 2022 bag law, which bans plastic carryout bags at stores and food service businesses and paper carryout bags at grocery stores of 2,500 sq ft or more.
See: paper bag regulations by market
Prior sanction (US)
A prior sanction is an approval the FDA or the US Department of Agriculture gave for a specific use of a substance before the 1958 Food Additives Amendment. It remains a valid legal basis for that use in food-contact materials, but only for the exact substance and use sanctioned.
See: food-contact packaging compliance
State packaging EPR laws (US)
At least seven US states have packaging EPR laws: California (SB 54), Oregon (programme operating from July 2025), Colorado (producer invoices in 2026), Maine, Minnesota, Maryland and Washington. The producer is typically the brand owner, or the importer or distributor if the brand has no US presence, and each state sets its own registration, reporting, fee and small-producer rules.
See: US foodservice packaging regulations
State PFAS food packaging bans (US)
Many US states ban intentionally added PFAS in food packaging, including New York (31 December 2022), California under AB 1200 (1 January 2023), Washington (phased 2023 and 2024), Vermont (1 July 2023), Connecticut (31 December 2023), Colorado, Maryland and Minnesota (1 January 2024), Hawaii (31 December 2024), Rhode Island and Oregon (1 January 2025) and Maine (25 May 2026, nine plant-fibre packaging types). The practical national baseline is no intentionally added PFAS, often screened with a total organic fluorine threshold of about 100 ppm.
Customs, origin and Incoterms
Classification, origin, duty and trade-term vocabulary for imported packaging, with the EU-Türkiye and UK-Türkiye arrangements as worked examples. The full guide is sourcing packaging from Türkiye.
A.TR movement certificate (EU-Türkiye)
An A.TR is the movement certificate that proves goods are in free circulation in the EU-Türkiye Customs Union, allowing industrial goods such as paper packaging (HS 48) and plastic bags and pouches (HS 3923) to enter the EU without customs duty. It is not a certificate of preferential origin, it is not used for UK imports, and import VAT remains payable; without a valid A.TR at import, duty can be charged until one is presented.
See: sourcing packaging from Türkiye
CBAM (EU; Carbon Border Adjustment Mechanism)
CBAM is the EU mechanism that puts a carbon price on imports of certain carbon-intensive goods, such as iron and steel, cement, fertilisers and aluminium. Paper and plastic packaging are not covered, although aluminium products such as foil fall within its scope.
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CFR (Cost and Freight; Incoterm)
CFR is a sea-only Incoterm under which the seller clears goods for export and pays freight to the named destination port, but risk passes to the buyer once the goods are loaded on the vessel at the port of shipment. It is CIF without the seller's insurance obligation, so the buyer should arrange cargo insurance from loading.
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CIF (Cost, Insurance and Freight; Incoterm)
CIF is a sea-only Incoterm under which the seller pays freight and minimum insurance cover to the named destination port, but risk passes to the buyer once goods are loaded on the vessel at the port of shipment. The buyer handles import clearance, duty and VAT, and should check whether minimum cover is enough for the cargo value.
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CIP (Carriage and Insurance Paid To; Incoterm)
CIP is an Incoterm for any mode of transport under which the seller pays carriage and insurance to a named destination, but risk passes to the buyer when the goods are handed to the first carrier. Under Incoterms 2020 the seller must provide broader insurance cover under CIP than under CIF, which makes CIP the multimodal alternative for containerised cargo handed over inland.
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CN code (EU Combined Nomenclature; DE: Zolltarifnummer)
The CN code is the EU's eight-digit customs classification, built on the six-digit HS code; the EU's TARIC database extends it to ten digits for import measures and is used on import declarations. Paper boxes and bags fall mainly under heading 4819 and plastic bags and pouches under 3923, and the code drives duty, statistics and any product-specific import measures.
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Country-of-origin marking (US; 19 CFR Part 134)
Under 19 CFR Part 134, articles imported into the US, or in some cases their outer containers, must be marked with the country of origin in English, legibly and permanently. The exact marking and spelling, for example for goods made in Türkiye, should be agreed with the customs broker before cartons are printed.
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CPT (Carriage Paid To; Incoterm)
CPT is an Incoterm for any mode of transport under which the seller pays carriage to a named destination, but risk passes to the buyer when the goods are handed to the first carrier. It suits containerised cargo handed over at an inland depot better than CFR, and the buyer arranges insurance.
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Customs bond (US)
A customs bond is a financial guarantee, issued by a surety and posted with US Customs and Border Protection, that the importer will pay duties, taxes and penalties owed. It is required for formal entries and can be a single-entry bond for one shipment or a continuous bond covering a year of imports.
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Customs union (EU-Türkiye; Decision 1/95)
A customs union is an arrangement in which members remove customs duties between themselves and apply a common external tariff. The EU-Türkiye Customs Union, established by Association Council Decision 1/95, lets industrial goods in free circulation move between Türkiye and the EU without customs duty when accompanied by an A.TR; it does not remove import VAT and does not apply to UK trade.
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DAP (Delivered at Place; Incoterm)
DAP is an Incoterm under which the seller arranges transport to a named destination and bears risk until the goods arrive ready for unloading there, while the buyer unloads and handles import clearance, duty and VAT. It is common for road freight from Türkiye to EU warehouses.
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DDP (Delivered Duty Paid; Incoterm)
DDP is the Incoterm under which the seller delivers to the named destination and also handles import clearance, duty and VAT. It requires the seller to act as importer, which can mean VAT registration in the destination EU country or a non-resident importer arrangement in the US, so what the price includes should be confirmed in writing.
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De minimis (US customs)
De minimis is the value threshold below which imported goods enter free of duty and with simplified formalities. In the US the duty-free treatment of low-value parcels has been suspended, so even small sample shipments of packaging can attract duty and entry formalities.
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DPU (Delivered at Place Unloaded; Incoterm)
DPU is an Incoterm under which the seller delivers and unloads the goods at a named destination and bears risk until they are unloaded, while the buyer handles import clearance, duty and VAT. It replaced DAT in Incoterms 2020 and is the only rule that makes the seller responsible for unloading.
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EORI number (EU/UK)
An EORI (Economic Operators Registration and Identification) number identifies a business to customs authorities in the EU or UK and must appear on import and export declarations. An importer of packaging needs one before its first shipment; GB uses its own EORI numbers, separate from EU ones.
See: sourcing packaging from Türkiye
EUR.1 movement certificate
An EUR.1 is a movement certificate proving the preferential origin of goods under a free trade agreement, issued by the exporting country's customs or chamber. For UK imports from Türkiye under the UK-Türkiye FTA it is one of two accepted proofs of origin, the other being an origin declaration on the invoice.
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EXW (Ex Works; Incoterm)
EXW is the Incoterm under which the buyer takes over cost and risk at the seller's premises, before loading, and is responsible for export clearance in the seller's country. Because foreign buyers are often not set up to clear exports there, FCA at the seller's premises usually achieves the same result with fewer problems.
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FCA (Free Carrier; Incoterm)
FCA is the Incoterm under which the seller clears goods for export and hands them to the buyer's carrier at a named place, where risk passes to the buyer. It suits containerised and road shipments better than FOB when goods are handed over before being loaded on a ship.
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FOB (Free On Board; Incoterm)
FOB is a sea-only Incoterm under which the seller clears goods for export and bears risk until they are loaded on the vessel at the named port of shipment. The buyer pays main freight, insurance and all import costs; for containers handed over at a terminal, FCA fits the risk transfer better, although FOB remains widely used.
See: sourcing packaging from Türkiye
HS code (Harmonized System; US: HTS code)
An HS code is the six-digit product classification of the World Customs Organization's Harmonized System, used by almost every customs authority and extended nationally as the CN code in the EU, the commodity code in the UK and the HTS code in the US. Paper packaging falls mainly in chapter 48 and plastic bags and pouches in heading 3923; the code determines duty, documentation and trade statistics.
See: sourcing packaging from Türkiye
HTS code (US; Harmonized Tariff Schedule)
The HTS code is the ten-digit US classification in the Harmonized Tariff Schedule, maintained by the US International Trade Commission. Printed packaging falls typically under 4819 for boxes and bags, 4823.69 for paper cups, 4811 and 4806 for coated and greaseproof papers and 3923 for plastic bags and pouches; because additional tariffs have changed repeatedly since 2025, the current rate must be checked at hts.usitc.gov and with a licensed customs broker at the time of order.
See: US foodservice packaging regulations
Import VAT (DE: Einfuhrumsatzsteuer; NL: invoer-btw)
Import VAT is value added tax charged when goods enter a country, separate from customs duty: for example 19 % in Germany, 20 % in Austria and the UK and 21 % in the Netherlands. VAT-registered businesses can usually recover it, but it affects cash flow; in the Netherlands an Article 23 licence lets importers defer it to the VAT return instead of paying at the border.
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Importer of record (IOR; US)
The importer of record (IOR) is the party legally responsible for an import's entry, duties, customs bond, Importer Security Filing, country-of-origin marking and recordkeeping, typically the buyer or its appointed party for US imports. It is often also the EPR producer when the brand has no US presence, and under DDP terms the seller has to take the role.
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Incoterms 2020 (ICC trade terms)
Incoterms 2020 are the International Chamber of Commerce's eleven standard trade rules defining where the seller's costs, risks and customs duties end and the buyer's begin: EXW, FCA, CPT, CIP, DAP, DPU and DDP for any mode of transport, and FAS, FOB, CFR and CIF for sea and inland waterway only. The rule and the named place should be fixed in each quotation, and offers from different countries compared on the same term.
See: sourcing packaging from Türkiye; packaging cost drivers
ISF (Importer Security Filing; 10+2; US)
ISF, known as 10+2, is the US requirement for the importer to file ten data elements, and the carrier two, before ocean cargo is loaded at the foreign port. Late, inaccurate or missing filings can be penalised, so the supplier's shipment data should reach the importer or broker before the container is loaded.
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Origin declaration (approved exporter)
An origin declaration is a statement of preferential origin made by the exporter on the commercial invoice or another commercial document under a free trade agreement such as the UK-Türkiye FTA. Above a value threshold, roughly €6,000 per consignment under that agreement, the exporter needs approved exporter status; below it any exporter may make the declaration.
See: sourcing packaging from Türkiye
Preferential origin (rules of origin)
Preferential origin is the status that qualifies goods for reduced or zero duty under a free trade agreement. It depends on meeting the agreement's product-specific rules of origin, for example a required change of tariff heading or a maximum share of non-originating material, and must be supported by proof of origin; packaging converted from imported paper or film may or may not qualify. Non-preferential origin, the "made in" country for marking and trade measures, is a separate concept.
See: sourcing packaging from Türkiye
UK-Türkiye Free Trade Agreement (UK-Türkiye FTA)
The UK-Türkiye FTA has governed trade between the two countries since 1 January 2021. Unlike the EU-Türkiye Customs Union, its reduced or zero duties depend on goods meeting product-specific rules of origin with an EUR.1 or an origin declaration; if origin cannot be proven, the UK Global Tariff rate applies, and UK import VAT of 20 % is payable on top.
Shipping, pallets and freight
Load units, freight documents and measures that determine landed cost. Palletisation is covered in sourcing packaging from Türkiye and shipping-box sizing in mailer box sizes.
Bill of lading (B/L; DE: Konnossement; NL: cognossement)
A bill of lading is the document issued by an ocean carrier that acts as a receipt for the goods, evidence of the contract of carriage and, when issued as a negotiable original, a document of title needed to release the cargo. A sea waybill is a non-negotiable alternative used when no title transfer is needed.
See: sourcing packaging from Türkiye
CBM (cubic metre)
CBM is the cubic metre, the unit used to measure freight volume. Less-than-container-load sea freight is usually charged per CBM or per tonne, whichever is greater, and a 20 ft container holds about 33 m³ internally, a 40 ft about 67 m³ and a 40 ft high-cube about 76 m³, though usable volume is lower once pallets and stacking are allowed for.
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CMR consignment note
The CMR consignment note is the standard road freight document under the Convention on the Contract for the International Carriage of Goods by Road, used on truck shipments such as Türkiye to EU warehouses. It records the goods, sender, carrier and consignee and is signed on collection and delivery, so damage or shortage should be noted on it at unloading.
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Dimensional weight (DIM weight; volumetric weight)
Dimensional weight is the chargeable weight carriers calculate from a parcel's volume, length × width × height divided by a divisor, and charge when it exceeds the actual weight. USPS changed its divisor from 166 to 139 cubic inches per pound on 12 July 2026 for parcels over one cubic foot, and international express services commonly use 5,000 cm³ per kg, so oversized mailer boxes cost more to ship as well as breaching the PPWR empty space rule from 2030.
See: mailer box sizes
Euro pallet (EUR/EPAL; 1200 × 800 mm; DE: Europalette)
The Euro pallet is the standard European wooden pallet measuring 1200 × 800 mm, made and marked to EPAL or equivalent rules. Thirty-three fit single-stacked on a 13.6 m trailer, which makes it the default for road freight from Türkiye to the EU; a 40 ft container typically takes around 23 to 25 per tier depending on pattern.
See: sourcing packaging from Türkiye
FCL and LCL (full and less than container load; road: FTL and LTL)
FCL (full container load) means the shipper books a whole container, while LCL (less than container load) consolidates several shippers' cargo in one container and charges per CBM or tonne. LCL suits smaller orders but adds handling at consolidation and deconsolidation warehouses; on road freight the equivalents are FTL (full truckload) and LTL (part load).
See: sourcing packaging from Türkiye
GMA pallet (US; 48 × 40 in)
The GMA pallet, named after the former US Grocery Manufacturers Association, is the standard US pallet measuring 48 × 40 inches, about 1219 × 1016 mm. US warehouses and racking are built around it, so shipments to US distribution centres should be palletised to 48 × 40 in; typically about 10 fit in a 20 ft and 20 in a 40 ft container.
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ISPM 15 (wood packaging material standard)
ISPM 15 is the International Plant Protection Convention standard requiring wood packaging in international trade, such as pallets and crates, to be treated against pests, typically by heat treatment to a core temperature of 56 °C for 30 minutes, and marked with the IPPC symbol, country code, producer number and treatment code (HT for heat treatment). Processed wood such as plywood and presswood pallets is exempt, and destination requirements should be confirmed with the forwarder.
See: sourcing packaging from Türkiye
Landed cost
Landed cost is the total cost of getting packaging to the buyer's warehouse: factory price plus freight, insurance, customs duty, non-recoverable taxes, clearance and broker fees, port and handling charges and inland delivery. Because freight is charged per pallet space, trailer or container, units per pallet often move landed cost per thousand as much as the factory price.
See: packaging cost drivers; sourcing packaging from Türkiye
TEU (twenty-foot equivalent unit)
A TEU is the standard unit of container capacity, equal to one 20 ft container; a 40 ft container counts as two TEU (FEU). Shipping lines and ports quote capacity and some rates in TEU, while packaging buyers usually book by container type: 20 ft, 40 ft or 40 ft high-cube, the last being about 30 cm taller and useful for light, bulky items such as nested cups.
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UK standard pallet (1200 × 1000 mm; ISO industrial pallet)
The UK standard pallet measures 1200 × 1000 mm and is also used in parts of continental Europe as the ISO industrial pallet. Twenty-six fit on a 13.6 m trailer and around 20 to 21 per tier in a 40 ft container, and UK distribution centres often expect it, so the pallet size should be agreed before production.
Next step: put the terms into your specification
Most of these terms map to a line on a packaging specification or a request for quotation: countries of supply and who is manufacturer, importer and producer in each; food-contact conditions and the documents required; PFAS and recycled-content evidence; claims and marks to be printed; Incoterm, named place, pallet standard and proof of origin. The packaging RFQ guide sets out the full checklist, and for a buyer's view of the cost side, see packaging cost drivers.
9 Packaging is an Istanbul-based manufacturer and exporter of printed packaging for business customers, with experience supplying fast-food and chain-style foodservice operations. If a term in a compliance request, supplier document or export quotation is unclear, send it with your enquiry through our contact page; the documents and data that accompany each item are agreed at quotation and technical review.