A compliance manager sorting the packaging inventory for a restaurant group will hit this question sooner or later: the tray liner is paper, it carries the brand, food sits on it, and it is thrown away after the meal, so is it packaging, a food-contact article or neither? The answer decides whether the weight goes into an EPR report, whether PFAS limits apply and what documents a supplier should provide. This guide sets out how to reason about it for custom printed tray liners in the EU, Germany, the UK and the US. It is information, not legal advice; confirm the position for your own role with the competent authority or your compliance scheme.
Are tray liners legally packaging?
Sometimes. No rule names tray liners across all markets, so the answer comes from the function test that packaging definitions use. A liner that holds, serves or presents food at the point of sale looks more like packaging than a placemat sold separately as a table accessory. Because the position can differ by country and scheme, operators should record how they classified the item and why.
In the EU, Regulation (EU) 2025/40 (the PPWR, in force from 11 February 2025 and generally applicable from 12 August 2026) defines packaging by function: an item used for the containment, protection, handling, delivery or presentation of goods. Annex I is an indicative list of examples for borderline items. It ties several of them to whether they are designed and intended to be filled at the point of sale (paper carrier bags, disposable plates and cups, sandwich bags) or sold with the product (cake doilies sold with a cake are packaging, cake doilies sold without a cake are not). Annex I does not name tray liners or paper placemats, so their status follows the Article 3(1) definition and national practice. Read the current Annex I text on EUR-Lex before relying on this summary.
| Use of the liner | Likely treatment | Why |
|---|---|---|
| Lines a tray on which served food is carried to the customer | May be treated as service packaging | It supports and presents food that is sold to the customer |
| Wraps or separates food inside a bag or box (greaseproof sheet) | Packaging | It contains and protects the product |
| Paper placemat laid on a table, not touched by food | Often not packaging | It protects the table, not the goods; position depends on the scheme |
| Promotional placemat sold or supplied as an advertising item | Often not packaging | Its main function is advertising or decoration |
| Liner supplied to a canteen where food sits directly on it | Possibly packaging; a food-contact article in any case | Food contact and presentation of the food |
The table shows tendencies, not rulings. Where a scheme or authority publishes a catalogue of items, its decision on tray liners prevails over any general reasoning.
Do tray liners fall under EPR schemes?
If a tray liner counts as packaging, the responsible company must usually register and pay a fee based on weight and material. Who that company is depends on the country. For printed liners, the brand owner or the operator that supplies the item to its customers is often treated as the responsible party, not the foreign paper converter.
- Germany: the VerpackDG (Verpackungsrecht-Durchführungsgesetz) replaced the VerpackG from 12 August 2026. Registration in LUCID and participation in a dual system are required for system-participation packaging, and obligations for service packaging are connected to the party that supplies it. According to ZSVR guidance, from 12 August 2026 the buyer of service packaging bearing its own name, logo or brand is treated as producer and manufacturer, and pre-licensing by an upstream supplier is possible only in narrow exceptions under section 7(2); a foreign maker of branded packaging cannot pre-license it. The ZSVR publishes a Katalog of products with decisions on system participation; check whether it contains a sheet for tray liners and placemats and follow it. See packaging compliance in Germany and Austria.
- Austria: the Verpackungsverordnung and collection systems such as ARA apply; foreign manufacturers may appoint an authorised representative, but the position for serving items follows the same classification question.
- Netherlands: Verpact (formerly Afvalfonds Verpakkingen) administers producer responsibility; see packaging compliance in the Netherlands.
- United Kingdom: packaging EPR (pEPR) applies to producers above the turnover and tonnage thresholds, and service packaging has special rules; a non-UK manufacturer is not the producer, while a UK importer or brand owner may be. See UK packaging regulations.
- United States: state packaging EPR laws (for example California SB 54, Oregon, Colorado) place obligations on producers, typically the brand owner, and definitions vary by state; see US foodservice packaging regulations.
Obligations depend on your role and on thresholds, so confirm with your scheme. The EU-level overview is in PPWR explained for foodservice and e-commerce packaging buyers.
Are printed tray liners food-contact materials?
Yes, when food or its wrapper can touch the sheet. In that case the liner has to meet food-contact law whether or not it also counts as packaging. In the EU the framework is Regulation (EC) 1935/2004 (safety, labelling, traceability) and Regulation (EC) 2023/2006 (good manufacturing practice, including rules on printing inks and set-off). There is no harmonised EU measure for paper and board, so buyers commonly expect a declaration referring to Regulation 1935/2004 and the BfR Recommendation XXXVI.
For printed liners, the key point is that the printed face is often the side that touches the food. This differs from a wrap, where print normally sits on the outer face.
- Ask for a declaration of compliance covering the paper, inks and any coating
- Ask whether inks are suitable for the way the liner is used and whether set-off is controlled
- In Germany the printing ink ordinance (Druckfarbenverordnung) applies from 1 January 2027 after a transition
- In the US, paper that contacts food must meet FDA rules, such as 21 CFR 176.170 for aqueous and fatty foods and 176.180 for dry food, and the substances used must be authorised
In the UK, assimilated versions of the EU framework regulations apply in Great Britain, and Northern Ireland follows EU rules under the Windsor Framework. The wider picture is in food-contact packaging compliance in the EU, UK and US.
Do PFAS rules apply to tray liners?
If the liner is food-contact packaging or a grease-resistant food-contact paper, treat PFAS rules as applicable and specify it as fluorine-free. From 12 August 2026 the PPWR (Article 5(5)) limits PFAS in food-contact packaging to 25 ppb for any single PFAS, 250 ppb for the sum of PFAS and 50 ppm for all PFAS including polymeric PFAS, with no sell-off period. Several US states also restrict PFAS in food packaging.
Practical points:
- If a liner is classed as packaging, the PPWR PFAS limits apply directly in the EU
- If it is not, buyers should still expect the same fluorine-free standard, because food-contact safety and customer expectations do not depend on the packaging classification
- In the US, the FDA announced in February 2024 that PFAS grease-proofing agents were no longer being sold for food-contact use, and state laws such as those in California, New York and Maine apply to food packaging
- Great Britain has no PFAS restriction equivalent to the PPWR, but customers and retailers often ask for PFAS-free statements regardless
- Ask for a PFAS declaration and, where relevant, test results from an accredited laboratory
Greaseproof tray liners made from dense, refined fibre can reach their oil resistance without fluorinated chemistry. Specify fluorine-free grades; the details are in PFAS-free food packaging and the measurement background in KIT test and grease resistance ratings explained.
What else applies: labelling, recyclability and claims?
Several PPWR obligations apply to items that count as packaging, and green-claims rules apply to any liner marketing.
- Labelling: the harmonised sorting label is due from 12 August 2028 or 24 months after the implementing act, whichever is later; the implementing act has not been confirmed, so the date is open. See PPWR labelling requirements
- Recyclability: PPWR design-for-recycling criteria are due in 2028 and packaging must reach recyclability grade A, B or C from 1 January 2030; plain paper liners without plastic layers are generally in the easier group, but food contamination and local collection rules matter. See PPWR recyclability grades
- Plastic content: PE-coated or laminated paper liners add plastic, which can raise Single-Use Plastics Directive questions and affects recyclability under the PPWR, so unlined paper is simpler where grease resistance allows it
- Claims: Directive (EU) 2024/825 applies from 27 September 2026 and restricts generic environmental claims such as "eco-friendly" or "green"; in Great Britain the CMA Green Claims Code and the DMCC Act 2024 apply. Avoid unqualified claims on liner artwork; see recyclable, compostable and biodegradable packaging
What documents should you ask a tray liner supplier for?
Ask for the documents that match how you classified the item, and keep them with the artwork approval. A supplier can provide material and weight data; the legal responsibility for registration usually stays with the buyer or brand owner.
- Declaration of compliance for food contact (paper, inks, coatings)
- PFAS or fluorine-free declaration and, if required, test report
- Material composition and weight per sheet, to support EPR reporting
- Ink and coating information
- Confirmation of printed sample approval
- For importers: customs and origin documents, covered in sourcing packaging from Türkiye
Use the free PPWR compliance checklist to organise your own inventory. Return to the tray liner hub for specifications, or ask about documentation for a quotation.