PPWR Explained for Foodservice and E-commerce Packaging Buyers

What is the PPWR and when does it apply?

The PPWR is an EU regulation that replaces the Packaging Directive with directly applicable rules on packaging design, labelling, reuse and producer responsibility. It entered into force on 11 February 2025 and applies generally from 12 August 2026, with many design requirements phased in from 2028, 2030, 2035 and 2038.

Because it is a regulation, the core requirements apply in every Member State without national transposition. National laws still organise extended producer responsibility (registration, fees, collection systems) and some national measures continue alongside it. Germany's VerpackDG is an example, covered in our guide to packaging compliance in Germany and Austria.

PPWR timeline for foodservice and e-commerce packaging

Who is responsible under the PPWR?

The PPWR assigns duties to defined economic operators: manufacturer, producer, importer, distributor and authorised representative. One company can hold several roles, and the role can differ by country. For custom printed packaging, the brand owner is often the "manufacturer", while the "producer" for EPR is the operator who first makes the packaging available in each Member State.

Brand owner or restaurant chain

If you order cups, wraps or boxes printed with your brand, you may be the PPWR manufacturer of that packaging even though a converter makes it. That means you need access to the technical documentation and an EU Declaration of Conformity that covers your items. The manufacturer definition includes a nuance for micro-enterprises, and its application to empty printed packaging supplied to a food business is still being clarified in guidance, so check how your national authority applies it. In many cases you will also be the EPR producer for the service packaging you hand to customers, and national pre-licensing routes have narrowed (in Germany, the ZSVR says buying pre-licensed service packaging is no longer possible in most cases).

Importer

If you import unfilled printed packaging from outside the EU (for example from Türkiye), you are the importer. Before placing it on the market, check that the manufacturer has done the conformity assessment, that the DoC and technical documentation exist and that the packaging carries the required information, and add your name and address. Importers often also become the EPR producer in the country of first supply.

Distributor

Wholesalers and cash-and-carry suppliers must verify that what they sell carries the required documentation and labelling and must not sell packaging they know to be non-compliant. Distributors who put packaging on the market under their own name become manufacturers.

Foreign manufacturer

A manufacturer outside the EU must design and produce to PPWR requirements, prepare technical documentation and support the Declaration of Conformity. If it sells directly to end users in a Member State, it is the producer there and must appoint an EPR authorised representative. When it sells through an EU importer or to an EU brand owner who imports, the importer or brand owner usually carries the market-facing duties.

What does the PPWR require for foodservice packaging?

For takeaway and dine-in packaging, the main PPWR requirements are PFAS limits for food-contact packaging, the reuse and bring-your-own duties for takeaway outlets, the 2030 restrictions on single-use plastic packaging used on HORECA premises, and recyclability grades for all packaging from 2030.

PFAS (Article 5)

From 12 August 2026, food-contact packaging must not exceed 25 ppb for any single PFAS or 250 ppb for the sum of PFAS (both by targeted analysis), or 50 ppm for all PFAS including polymeric PFAS; if total fluorine exceeds 50 mg/kg, the supplier of the material must, on request, provide the packaging manufacturer or importer with proof of how much of the fluorine is PFAS or non-PFAS. There is no sell-off period. See our PFAS-free food packaging guide for tests and alternatives.

Bring-your-own and reusable offer (Articles 32 and 33)

From 12 February 2027, final distributors in the HORECA sector selling takeaway food or drinks must let customers fill their own containers at no higher price than single-use packaging. From 12 February 2028, they must offer a reusable packaging option at no higher price, with micro-enterprises exempt, and from 2030 they should endeavour to offer 10 % of products in reusable formats. For chains this is a store operations change, but it affects single-use volumes and the mix of cups and containers you order.

Annex V restrictions from 2030

From 1 January 2030 Annex V restricts several single-use formats, including single-use plastic packaging for food and drink filled and consumed on HORECA premises and single-use plastic condiment portions in HORECA (except where supplied with takeaway food). The PPWR does not define "single-use plastic packaging". In its guidance notice of 5 June 2026 (C(2026) 3702), the Commission interprets Annex V points 1-4 as covering composite packaging, including paper-based packaging containing 5 % or more plastic by weight, while packaging with no more than 5 % plastic is not covered. The guidance is not legally binding (a binding interpretation can only come from the Court of Justice), but PE-lined paper cups and containers at or above that level should be planned as in scope for dine-in use from 2030. Under the SUP Directive, plastic-lined paper is a single-use plastic product regardless of the plastic share.

Recyclability (Article 6)

From 1 January 2030 (or 24 months after the design-for-recycling delegated acts, if later) all packaging must be recyclable and reach grade A (at least 95 %), B (at least 80 %) or C (at least 70 %) under criteria to be adopted by 2028; from 2035 it must also be recycled at scale, and from 2038 only grades A and B remain. EPR fees will be modulated by grade, so the grade affects cost before it affects legality. For printed paper packaging, the barrier layer, windows, laminates and heavy metallic finishes are the usual points to review. Coating options are compared in our guide to barrier coatings for paper packaging.

Recycled content (Article 7)

From 1 January 2030, or three years after the implementing act on calculation and verification if that is later, plastic packaging must contain minimum recycled content: 30 % for contact-sensitive PET, 10 % for contact-sensitive non-PET, 30 % for single-use plastic beverage bottles and 35 % for other plastic packaging, rising to 50/25/65/65 % in 2040. This matters for plastic carrier bags, pouches, cup lids and container lids, not for paper.

Compostable packaging (Article 9)

Only tea and coffee bags and pods, fruit stickers and, if a Member State chooses, very lightweight and lightweight plastic carrier bags must be compostable. All other packaging must be recyclable, so a "compostable" cup or container does not escape the recyclability requirement. Claims rules are covered in our guide to recyclable, compostable and biodegradable packaging.

What does the PPWR require for e-commerce packaging?

E-commerce packaging is affected mainly by the empty-space limit, packaging minimisation, the harmonised label and the recyclability grades. The empty-space rule applies to the operator who fills the packaging, not to the box manufacturer.

• Empty space (Article 24): maximum 50 % empty space in grouped, transport and e-commerce packaging, from 1 January 2030 or three years after the Commission's calculation methodology act, whichever is later. Void fill counts as empty space.
• Minimisation (Article 10): weight and volume reduced to the minimum needed for function from 2030.
• Labelling (Article 12): the harmonised material sorting label applies to e-commerce packaging too.
• Transport packaging reuse (Article 29): 40 % reusable target by 2030, with cardboard boxes exempt.

Box sizing strategy and void-fill choices are covered in our article on e-commerce packaging and the PPWR; for pouches, see recyclable mono-material pouches and the PPWR.

When do the PPWR labelling rules apply?

The harmonised sorting label under Article 12 applies from 12 August 2028 or 24 months after the Commission adopts the implementing act setting the label, whichever is later. The Commission missed its 12 August 2026 deadline to adopt that act, and as of October 2026 no adoption had been confirmed, so the label will in practice apply later than 12 August 2028: 24 months after the act enters into force. Compostable packaging will need to state that it is not suitable for home composting.

Plan artwork so that a label panel can be added without redesign, and avoid committing to large reprints of long-life stock just before the label becomes mandatory.

Declaration of Conformity and technical documentation

The manufacturer must carry out conformity assessment, draw up technical documentation and an EU Declaration of Conformity, and keep them for 5 years for single-use packaging or 10 years for reusable packaging. The importer checks the DoC and adds its own name and address.

Technical documentation typically describes the packaging, its materials and design, how each applicable requirement is met (substances including PFAS, recyclability, minimisation, recycled content where relevant) and the test reports and supplier declarations relied on. The food-contact Declaration of Compliance under Regulation 1935/2004 and 10/2011 is a separate document (see food-contact packaging compliance).

How does the PPWR interact with national EPR?

The PPWR sets common EPR rules, but registration, reporting, fee payment and collection systems are still run nationally. A chain operating in Germany, Austria and the Netherlands must register and report in each country under its own scheme: LUCID and a dual system in Germany, a collection system such as ARA in Austria, and Verpact (formerly Afvalfonds Verpakkingen) in the Netherlands.

In the Netherlands, reporting and fee duties apply above 50,000 kg per year, with no threshold for single-use plastic products. Dutch rules on single-use cups and containers also continue: on-site consumption of single-use cups and containers (including PE-lined paper) has been banned since 1 January 2024. The to-go surcharge introduced in July 2023 was reported in a December 2025 letter to Parliament as not enforced in 2026 and to be abolished from 1 January 2027, while the existing duty to offer a reusable option or accept customers' own containers stays; the amending decree was not yet published as of October 2026. Cup-specific rules across Europe are covered in paper cup rules in Europe and the UK.

National SUP Directive measures (Directive (EU) 2019/904) also remain, including the "plastic in product" marking on PE-lined cups and SUP EPR including litter costs.

Documents to request from your packaging manufacturer

• EU Declaration of Conformity for each item, or the information you need to draw one up if you are the manufacturer.
• Technical documentation summary (materials, weights, design, how each requirement is met).
• PFAS statement and test reports for food-contact items.
• Material composition and weight per component for EPR reporting in each country.
• Recyclability evidence: mill or test-lab statement on repulpability of coated papers; mono-material confirmation for flexible packaging.
• Recycled content declaration for plastic components where relevant (ahead of 2030).
• Food-contact DoC under 1935/2004 and, where applicable, 10/2011.

At 9 Packaging, the documentation package for each item is agreed during quotation and technical review, since it depends on materials, construction and the countries where the packaging will be placed on the market.

What this means for packaging you order now

• Paper cups: plan for reuse duties from 2027-2028 and plan for the Annex V dine-in restriction from 2030, which Commission guidance applies to PE-lined cups containing 5 % or more plastic. See custom printed paper cups.
• Takeaway boxes and food containers: PFAS-free barriers now; recyclability grade before 2030. See custom printed takeaway food boxes.
• Mailer boxes: right-size the range now to prepare for the 50 % empty-space rule. See custom printed mailer boxes.
• Pouches and plastic bags: mono-material structures and recycled content planning for 2030. See custom printed stand-up pouches.

Next step: build a PPWR file for each packaging item

Start with an inventory: for each item, record material, weight, coating, food contact yes/no, countries of supply and who is the manufacturer, importer and producer. Then request the documents above from your supplier. If you are specifying new packaging, include the PPWR requirements and target countries in your request for quotation or send them via our contact page for technical review.

Related reading

• Packaging glossary: paper, board, print and compliance terms
• Packaging Compliance in the Netherlands: Verpact, Waste Management Fee and Single-Use Cup Rules
• PPWR Declaration of Conformity: What It Must Contain and Who Signs It
• PPWR Recyclability Grades Explained: A, B, C and the 70 % Floor
• PPWR Labelling Requirements: Harmonised Sorting Labels, Timelines and Who Must Label
• Packaging Regulation, Sustainability and Trade Glossary

For a dated, article-referenced action list you can print and tick off, download the PPWR compliance checklist.