Paper Cup Rules in Europe and the UK: SUP Marking, Levies and Reuse

Who is responsible for paper cup compliance?

Responsibility depends on your role in each market, not on who printed the cup. The brand owner whose name is on a custom printed cup, the importer that first places cups on a national market and the outlet that hands drinks to customers can each carry different obligations.

A supplier outside the EU or UK selling to a chain's importing entity normally is not the producer, but it should supply accurate weights, material breakdowns and compliance documents so the producer can report and pay correctly.

What does the EU Single-Use Plastics Directive require for paper cups?

Under the SUP Directive (EU) 2019/904, a paper cup with a plastic lining or coating is a single-use plastic beverage cup. Since 3 July 2021 it must carry the printed "Plastic in product" marking defined in Commission Implementing Regulation (EU) 2020/2151, and cups fall under EPR schemes that include litter clean-up costs and national measures to reduce consumption.

Why a paper cup counts as a plastic product

The Commission's SUP guidelines (2021/C 216/01) state that paper or board products with a plastic lining or coating are single-use plastic products. A standard PE-lined cup is therefore in scope, and so is a PLA-lined cup, because bio-based and compostable plastics are still plastics under the Directive. Whether a cup with an aqueous dispersion coating is in scope depends on whether the coating meets the plastic definition; many dispersions are synthetic polymers. See paper cup linings: PE vs aqueous dispersion vs PLA. Cups made entirely of plastic are in scope of the same Directive, and the specific points for PET and PP cups are in single-use plastic cup rules.

Beverage cups made of expanded polystyrene, including their covers and lids, have been banned since 3 July 2021. Paper cups are not banned by the Directive.

The "Plastic in product" marking

Implementing Regulation (EU) 2020/2151 sets a harmonised marking for beverage cups: a pictogram with the words "Plastic in product" (or the equivalent text) in the official language or languages of the Member State where the cup is placed on the market. The Regulation's annex specifies the design, size and positioning, and the marking must be printed on the cup, not just on the outer carton.

Practical consequences for artwork:

• Each language market needs the correct text. A cup sold in Germany and Austria can use the German version; the Netherlands needs Dutch; Belgium may need more than one language.
• Multi-market cups can carry several language versions, which takes space on smaller sizes. Plan the panel early.
• Use the official artwork files from the Regulation's annex and check size and position rules on the smallest cup in the range first.
• The marking must sit on the visible outer surface, clear of the side seam and the rim and bottom curls.

Placement on a tapered cup is covered in paper cup printing and artwork on a tapered cup. Germany implements the marking duty through its Einwegkunststoffkennzeichnungsverordnung, but the design follows the EU Regulation.

What changes for paper cups under the PPWR?

The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, applies from 12 August 2026 alongside the SUP Directive. For cups, the most relevant parts are takeaway reuse duties from 2027 and 2028, recyclability grades from 2030 and harmonised labelling later in the decade.

One point matters for eat-in drinks. The PPWR does not define "single-use plastic packaging", and its definition of plastic refers to a polymer capable of functioning as a main structural component of packaging. However, the Commission's guidance notice of 5 June 2026 (C(2026) 3702) treats composite packaging, including paper-based packaging containing 5 % or more plastic by weight, as covered by the Annex V restrictions, while packaging with no more than 5 % plastic is not. The guidance is not legally binding, but a PE-lined cup at or above that level should be expected to fall under the restriction for drinks consumed on site from 1 January 2030. For the regulation as a whole, see PPWR explained.

Germany: plastic fund levy, reuse offer and registration

Germany adds three layers to the EU rules for cups: a single-use plastic fund levy charged per kilogram, a duty for takeaway outlets to offer reusable cups, and packaging registration under the VerpackDG, which replaced the VerpackG from 12 August 2026.

Einwegkunststofffondsgesetz (single-use plastic fund)

Producers of in-scope single-use plastic products, including plastic-lined beverage cups, have had to register on the DIVID platform since 1 January 2024. A levy has been charged since 2025, starting on 2024 quantities, at rates set in the EWKFondsV; the rate for beverage cups is €1.236 per kilogram. The levy is paid by whoever first places the cups on the German market, which is usually the importer. If your German entity imports cups directly from a manufacturer abroad, it is likely to be that party. The levy is calculated on the weight of the whole cup, including the paper, not only its plastic lining: the Umweltbundesamt's audit guidelines (Prüfleitlinien, February 2025) require the entire single-use plastic product to be weighed.

Mehrwegangebotspflicht (Mehrwegpflicht, reusable offer)

Since 1 January 2023, takeaway outlets that fill single-use plastic food packaging or single-use beverage cups of any material must also offer a reusable alternative at no higher price. The cup material does not create an exemption: a dispersion or fully paper cup still triggers the duty. Small outlets with no more than five employees and no more than 80 m² of sales area are exempt but must fill customers' own containers on request. The provisions now sit within the VerpackDG framework; check current section references with your adviser.

VerpackDG and LUCID

Registration in the LUCID packaging register (ZSVR) remains mandatory and cannot be delegated. Cups are service packaging (Serviceverpackungen). According to the ZSVR, an outlet buying cups printed with its own name, logo or brand is the producer, wherever the cups are made, and must license them itself; pre-licensing by an upstream supplier (§ 7(2) VerpackDG) remains only in narrow cases involving neutral packaging ordered from abroad and then branded or modified. See packaging compliance in Germany and Austria.

Austria

Austria applies the EU SUP marking and EPR rules. Packaging licensing runs under the Verpackungsverordnung 2014 (amended 2023) through collection systems such as ARA or Reclay. Since 1 January 2023, foreign distance sellers supplying private consumers in Austria must appoint an Austrian authorised representative (Bevollmächtigter, § 16b Verpackungsverordnung), and manufacturers established in another EU Member State may appoint one voluntarily to license packaging for Austrian business customers (§ 16a). For service packaging such as cups, the primary obligation sits with the Austrian manufacturer or importer of the packaging. National implementation of the PPWR is pending, and the existing system continues in the meantime.

The Netherlands: on-site ban and to-go rules

The Netherlands has the strictest cup rules in this group. Since 1 January 2024, single-use cups and food containers containing plastic, including PE-lined paper cups, may not be used for food or drinks consumed on the premises. Since 1 July 2023, outlets selling to go have had to offer a reusable option or accept customers' own cups and containers, and to charge a surcharge for single-use plastic ones. A limited exception for on-site use applies where cups and containers are collected for recycling (85%, rising to 90% from 2027); since 2026 it is limited to settings such as events and attractions and no longer covers offices.

According to a December 2025 letter to the Dutch Parliament, the to-go surcharge is not being enforced in 2026 and is due to be abolished from 1 January 2027; the duty to offer a reusable option or accept customers' own cups stays. The amending decree had not been published as of October 2026, so confirm it before you plan around it. EPR runs through Verpact (formerly Afvalfonds Verpakkingen); the general reporting threshold of 50,000 kg per year does not apply to SUP products.

For a chain, the Dutch rules mean eat-in service needs reusable cups or cups that contain no plastic, and to-go cups need the Dutch-language SUP marking.

United Kingdom: pEPR and what does not apply

Great Britain does not apply the EU SUP marking. Paper cups fall under UK packaging extended producer responsibility (pEPR), where the UK importer or brand owner, not a non-UK manufacturer, is the producer.

Packaging EPR

Businesses are obligated when they meet the producer tests (over £1m turnover, more than 25 tonnes of packaging handled, UK-established); large producers (over £2m and more than 50 tonnes) pay fees. Fees are administered by PackUK; year one base fees were invoiced from October 2025, and from year two (2026/27) fees are modulated by recyclability assessment (green, amber, red). Service packaging such as takeaway cups has specific rules on who reports. Fibre-based composite (PE-lined paper) cups are reported as their own material category with their own fee rates (PackUK's December 2025 illustrative year 2 fees were about £475, £525 and £630 per tonne for green, amber and red). The mandatory cup take-back scheme proposed earlier, which would have required sellers of filled fibre-based composite cups with 10 or more employees to collect cups for recycling, was cancelled by Defra in December 2024 across all four UK nations. See UK packaging regulations.

Plastic Packaging Tax, SUP bans and labelling

The Plastic Packaging Tax (£228.82 per tonne from 1 April 2026) applies to packaging where plastic is the heaviest material by weight, so standard paper cups are typically outside it; plastic lids are plastic packaging and can count towards an importer's PPT position. England's single-use plastics ban from 1 October 2023 covers expanded polystyrene food and drink containers including cups, not paper cups. Mandatory recyclability labelling has been removed from the regulations pending alignment, and OPRL labelling remains voluntary. Northern Ireland follows some EU rules under the Windsor Framework, so check its position separately.

United States in brief

The US has no federal equivalent of the SUP marking. Cup buyers mainly deal with FDA food-contact requirements, state PFAS bans, state packaging EPR laws (including California, Oregon and Colorado) and state rules on recyclability and compostability claims, such as California SB 343 (enforcement preliminarily enjoined by a federal court since 14 July 2026) and AB 1201 (USDA organic-input requirement for compostable labels, extended by CalRecycle to 30 June 2027 for products containing synthetic substances such as PLA). See US foodservice packaging regulations.

Summary by market

Compliance checklist before printing

• List every country where the cups will be used and the language(s) of the marking for each
• Confirm the lining and, for dispersion coatings, its status under the SUP plastic definition
• Identify the importer or first placer for each market and who pays EPR and, in Germany, the plastic fund levy
• Collect material and weight data per cup size (board, coating, any lid) for reporting
• Check LUCID registration for German outlets and Austrian licensing arrangements
• Review eat-in service in the Netherlands and the PPWR Annex V question for 2030
• Plan reuse offers and bring-your-own processes for 2027 and 2028
• Avoid generic environmental claims on the cup; see recyclable, compostable and biodegradable claims

When the regulatory requirements are clear, return to the custom printed paper cups specification list, or send 9 Packaging your markets and cup range so artwork variants and documentation can be planned with the quotation.

Related reading

• Packaging Compliance in the Netherlands: Verpact, Waste Management Fee and Single-Use Cup Rules
• Are Paper Cups Recyclable? Linings, Collection Systems and Claims