Wet Wipes and the Single-Use Plastics Rules: Marking, EPR and Levies

Are wet wipes single-use plastic products under EU law?

A wet wipe is a single-use plastic product under Directive (EU) 2019/904 when it is pre-wetted, meant for personal care or domestic use, and wholly or partly made of plastic. The Directive lists "wet wipes, i.e. pre-wetted personal care and domestic wipes" in its marking and producer-responsibility annexes.

Three tests decide it:

• Plastic. Article 3(1) defines plastic as a polymer that can function as a main structural component, excluding natural polymers that have not been chemically modified. Polyester, polypropylene and other synthetic fibres are plastic.
• Single-use and pre-wetted. A dry wipe is out; a pre-moistened towel intended to be thrown away is in.
• Personal care or domestic use. Recital 12 says personal care and domestic wipes are in scope and industrial wipes are not.

The Commission's guidelines on the Directive (Notice 2021/C 216/01, published 7 June 2021) give examples. A wipe containing plastic is included. A wipe made of viscose or lyocell with no polyester or other plastic is excluded, because those regenerated celluloses are not treated as chemically modified natural polymers. The guidelines are not binding law, but authorities and businesses use them, and a Member State's own reading can differ. Plastic-free wipe fibres are explained in Plastic-Free Wet Wipes.

Many restaurant towels are spunlace nonwovens that blend viscose with polyester. A blend contains plastic and is therefore in scope. Ask your wipe supplier for the fibre composition in writing.

Is a restaurant refreshing towel a personal care wipe?

Almost certainly yes, if it contains plastic. The Commission's guidelines list cleansing wipes for skin, including hands, as covered personal care wipes, and hand disinfection wipes are covered even when provided to consumers in aircraft, airports, trains or other venues.

The guidelines draw the line at professional use: medical wipes sold through professional channels, and industrial wipes for machine cleaning or janitorial work, are outside. They add that the point of purchase, distribution channel and type of end user matter. A towel bought by a restaurant in a business-to-business channel but handed to guests to clean their hands is used by non-professional consumers. A restaurant should assume the in-scope reading unless an authority tells it otherwise.

What marking do plastic-containing wet wipes need?

The pack must carry a printed "PLASTIC IN PRODUCT" marking, with a pictogram, on its front or top face. The specification is in Annex II of Implementing Regulation (EU) 2020/2151, which has applied since 3 July 2021, and the marking text must be in the official language of each Member State where the product is placed on the market.

Key rules from Annex II:

• Applies to the packaging of the wipes where the packaging surface is 10 cm2 or more. Sachets of all common restaurant sizes exceed that.
• Printed on the packaging; the marking may not be torn or made illegible when the pack is opened as instructed.
• Placed horizontally on the external front or top surface, whichever is more visible. If it cannot fit, it may be spread over two sides or turned 90 degrees.
• Composed of two equal red and blue boxes side by side with a black box below containing "PLASTIC IN PRODUCT". Height to length ratio 1:2.
• Where the face area is below 65 cm2, minimum size 1.4 x 2.8 cm (3.92 cm2). Otherwise at least 6 % of the face area, with a maximum required size of 3 x 6 cm.
• Text in upper case Helvetica Bold, 5 to 14 pt; 300 dpi minimum at actual size; white border; the Annex colours (red C0 M90 Y60 K0, blue C60 M0 Y0 K0, black K100).
• Additional-language text goes below the marking or in the black box.

The face area of the sachet therefore sets the size. The figures below apply the rule to the three common formats, taking the front face as the placement surface:

These figures are an arithmetic reading of the Regulation. Confirm the placement surface and any seal or fin area with your compliance contact before artwork is released. Plan the layout around the marking: it takes a visible share of a small face, it cannot be hidden on the reverse, and it must sit clear of the tear line.

The sachet is normally the sales unit, so the marking belongs on the sachet. The Implementing Regulation defines the packaging to be marked as sales packaging and grouped packaging (Article 1), so a multi-sachet pack or display box sold as a unit can need the marking too; confirm with the competent authority how it treats outer cartons in your market. In Germany the marking duty is implemented in the Einwegkunststoffkennzeichnungsverordnung (EWKKennzV), which refers to Annex II of the Implementing Regulation for wet wipes.

Which producer costs and levies apply to wet wipes?

Member States must set up extended producer responsibility for wet wipes under Article 8 of the Directive. Producers cover at least awareness-raising, the cost of cleaning up litter and the cost of data gathering and reporting. Unlike food containers and cups, the Directive does not require producers to fund separate waste collection for wipes.

Article 17 set 31 December 2024 as the application date for Article 8. The earlier date of 5 January 2023 applies only to schemes established before 4 July 2018 and to tobacco filters. How the cost is assessed and who pays differs by country; the schemes are national.

Germany is the case most restaurant buyers meet first. The Einwegkunststofffondsgesetz (EWKFondsG) lists wet wipes ("Feuchttücher, das heißt getränkte Tücher für Körper- und Haushaltspflege") in Annex 1 among the products subject to a levy into the fund run by the Umweltbundesamt (UBA).

• Who pays: the manufacturer who first places the product on the German market commercially, or who sells it directly from abroad to private households. UBA says foreign suppliers may appoint an authorised representative (Bevollmächtigter).
• Registration: through UBA's DIVID system. UBA states a sales ban for unregistered manufacturers applies from 1 January 2025.
• Rate: the levy rates are set in the Einwegkunststofffondsverordnung (EWKFondsV). The ordinance published in October 2023 lists wet wipes at 0.061 euro per kilogram. Rates can be revised, so check the current ordinance.
• Basis: the levy is charged per kilogram of the product placed on the market, on its whole weight rather than only its plastic share. How that weight is reported for wipes, in particular whether the lotion and the sachet count, should be confirmed with UBA or in the DIVID reporting guidance.

As scale: one million wipes at an assumed 5 g each is 5,000 kg, and at 0.061 euro per kilogram the levy is about 305 euro. At that rate the levy is small for a restaurant-size programme; the registration and reporting duty is the real task. Whether a free guest towel is a product for "Körper- und Haushaltspflege" placed on the market in the sense of the Act is a question to put to UBA or a compliance adviser before assuming a position.

For the Netherlands, Austria and other Member States, producer-responsibility rules for wipes are set nationally and not described here; see Packaging Compliance in Germany and Austria and Packaging Compliance in the Netherlands for the packaging side, and check the national single-use plastics provisions with the authority.

Are plastic wet wipes being banned in the UK?

Yes. Each UK nation has legislated to ban the sale and supply of wet wipes containing plastic, with different start dates. The restriction targets the wipe, not the sachet.

The England regulations define plastic in the same way as the EU Directive. GOV.UK guidance says wholesalers and manufacturers can continue to supply wipes containing plastic to businesses, charities and public sector organisations, but those wipes must not be supplied or sold on to individual customers, except by registered pharmacies. Wales states that business-to-business supply is not affected and the ban applies to supply to consumers. Enforcement differs by nation: local authorities in England, officers authorised by DAERA in Northern Ireland, with fines on conviction.

Free supply is covered. The English regulations define supply as "whether by way of sale or not", and DAERA's guidance for Northern Ireland says the ban applies whether wipes are sold or provided for free. None of the guidance names restaurants, hotels or airlines, but a restaurant that gives plastic-containing wipes to diners is supplying them to individual customers, and the safe reading is that the ban reaches it from the start dates. Defra publishes a contact for questions (wetwipes@defra.gov.uk). On fibres, DAERA describes plastic-free wipes as typically made of viscose, lyocell or cotton and says they are not included in the ban; the GOV.UK guidance for England reviewed here does not address viscose, so ask your authority before relying on it elsewhere.

A UK-wide programme therefore points to a plastic-free wipe, and the wipe fibre must be settled before sachets are printed for UK use. See UK Packaging Regulations for Foodservice and Retail Buyers for the sachet side.

Does the sachet also fall under single-use plastics rules?

Not under the wipe rules. The sachet is packaging and is regulated as packaging, including the EU Packaging and Packaging Waste Regulation (EU) 2025/40, which applies in general from 12 August 2026, and national schemes. A paper sachet with a polymer layer may raise separate questions on plastic content and recyclability.

For the packaging side, see PPWR Explained for Foodservice and E-commerce Packaging Buyers and PPWR Recyclability Grades Explained. For the wider SUP picture, see Food-Contact Packaging Compliance, and for the cup and container rules, Paper Cup Rules in Europe and the UK.

How should a restaurant decide?

Work through the questions in order; each answer narrows the next.

• Get the wipe fibre composition in writing. Any polyester, polypropylene or other synthetic fibre means the wipe contains plastic.
• List the markets of sale. EU Member State: marking in the local language on the sachet. Germany: also registration and levy. UK: the ban dates above.
• If the wipe contains plastic and the sachet is for the EU, add the marking to the artwork at the size your sachet requires, in each language needed. Use separate artwork for each language market.
• If you serve in the UK from the start dates, plan for a plastic-free wipe or confirm the supply position with the authority.
• Decide who registers, reports and pays: the brand owner, the importer or the wipe supplier. This is a contract point as well as a legal one.
• Keep sachet artwork and the wipe specification under one change control, so a change of fibre triggers a review of the marking.

9 Packaging prints the sachet. Who supplies the wipe and who holds registration and reporting duties for your market is agreed at quotation. Send the markets, the wipe composition and the sachet size through the contact page, and see the Custom Printed Wet Wipes hub for the wider specification. For general food-contact and SUP context, read Food-Contact Packaging Compliance in the EU, UK and US.