PPWR in Practice: What Is Really Changing in Your Industry
The new EU Packaging Regulation is often described as a major turning point. In your day-to-day operations, however, the picture is more nuanced: what matters to an ice cream parlour is completely different from what matters to a delivery service, while a canteen faces very different requirements from a butcher shop with counter sales. That is why this article is not another timeline of deadlines, but instead focuses on what you actually do in your business.
First, a distinction that causes a lot of confusion: The PPWR is not the 2021 plastics ban. Back then, the focus was on specific single-use plastic items – cutlery, straws, stirrers and expanded polystyrene containers. That was the SUPD, and we explained what it meant in our article on the EU single-use plastics ban. The PPWR takes a broader approach: It covers all packaging, regardless of the material, and sets out requirements for how packaging must be designed and how you are allowed to offer it. Both sets of rules continue to apply alongside each other.
The PPWR in Three Sentences
Regulation (EU) 2025/40 has applied directly in all Member States since 12 August 2026 – without the need for national implementing legislation in Germany. Its requirements take effect in stages: first limits on substances and documentation requirements, from 2027 the option for customers to have their own containers filled, from 2028 a reusable packaging option and harmonised labelling, and from 2030 material restrictions, recyclability requirements and recycled content targets. Germany’s Packaging Act will remain in place for the time being, but will gradually become less relevant.
So much for the theory. Now let’s get specific.
The Material Question: Three Routes, and One of Them Is a Dead End
The most important part of your planning is not about deadlines, but about materials. That is because, from 2030, exactly two criteria will determine whether a product can still be placed on the market: whether it contains plastic and where it is used.
| Material route | For on-site consumption from 2030 | For takeaway and delivery | Recycled content target achievable |
|---|---|---|---|
|
Fibre Uncoated or water-based coated paperboard, palm leaf, sugarcane, wood |
permitted | permitted | not applicable – no plastic |
|
rPET Recycled plastic |
not permitted |
permitted if recyclable |
yes – 30% for contact-sensitive PET |
|
PLA and other bioplastics |
not permitted |
permitted if recyclable |
no – does not count as recycled content |
|
Reusable in a pool system or with your own deposit scheme |
permitted |
permitted and a mandatory option from 2028 |
not applicable |
Two Conclusions Follow from This Table – and Getting Them Wrong Can Be Costly:
PLA is legally classified as plastic. The Regulation classifies polymers according to their structure, not according to the raw material they are made from. The fact that PLA is derived from plant starch and is industrially compostable does not change this. From 2030, PLA cups will be subject to the same restrictions on on-site consumption as PP or PS cups – and they do not count towards recycled content targets because recycled content must come from the recycling stream, not from agricultural raw materials.
rPET only solves half the problem. Its high recycled content is well suited to meeting the recycled content target from 2030 and makes it a solid choice for takeaway cold drinks. However, it does not change the restrictions for on-site consumption – single-use plastic remains single-use plastic, regardless of how much recycled material it contains. Businesses serving customers for on-site consumption will need to use fibre-based packaging or reusable alternatives.
The practical consequence is straightforward: for most businesses, it comes down to a two-part approach. Fibre-based packaging or reusable alternatives for anything served for consumption on the premises. A wider choice of materials – including rPET – for anything that leaves the premises.
Now let’s take a structured look at what this means for each industry:
Snack Bars and Food Trucks
A classic scenario: customers order at the window and eat at a standing table next to it. This is precisely where things can become legally tricky, because standing tables within your own business area count as on-site consumption – and from 2030, the ban on single-use plastic packaging applies there. If you only have a serving window and customers eat on the pavement, however, the food is considered takeaway.
What to check: Does the area where customers eat belong to your business? If so, plan to use fibre-based packaging or reusable alternatives for serving food. Paper chip trays and snack bags are already among the simplest options here.
Cafés and Ice Cream Parlours
The PPWR has a double impact here: from 2028, coffee-to-go cups must be offered with a reusable alternative, while ice cream cups used for consumption on the premises will fall under the on-site restrictions from 2030 if they are made of plastic. Ice cream parlours with seating should therefore consider switching to paperboard or reusable alternatives at an early stage.
What to check: What proportion of your sales is consumed on the premises? From around one third, setting up your own deposit system may be worthwhile compared with relying solely on single-use packaging.
Delivery Services & Takeaway
This is the most straightforward starting point: food that is delivered is not consumed on the premises, so the 2030 ban does not apply. Instead, the key requirements are recyclability from 2030 and – where plastic is involved – recycled content targets. The refill requirement from February 2027 only affects you when customers collect their orders from your premises.
What to check: Are your meal boxes and sauce containers classified as recyclable? Material combinations such as paperboard with a plastic window are the critical issue here, rather than the base material itself.
Bakeries & Patisseries
Bakeries will be noticeably affected by the refill requirement from February 2027, as customers frequently ask to use their own containers for baked goods and coffee. The organisational effort is relatively low, but the hygiene process needs to be clearly defined: there should be no contact between the customer’s container and tongs or dispensing equipment.
What to check: Is there a clearly defined procedure for customer-provided containers, and is the sales staff familiar with it? And is the required information displayed visibly at the counter?
Catering & Events
At events, the location is what matters, not your business: if food is consumed on the event premises, it counts as on-site consumption. This is why festivals and public events already predominantly use deposit systems. There is another point to consider: if you take on assignments in other EU countries, since August 2026 you have needed an authorised representative for extended producer responsibility there – there are no longer any de minimis thresholds.
What to check: Do you provide catering services across national borders? If so, registration in the destination country is more urgent than any question about materials.
Canteens & Cafeterias
This is the area most affected of all. Food is served at the counter and consumed in the dining area – this is on-site consumption in its clearest form, and wherever single-use plastic is currently used, it will need to be phased out by 2030. At the same time, the transition is often easier here because washing facilities are usually already available.
What to check: Where is single-use packaging still being used even though reusable items could be washed? Often, it is salad bowls, dessert cups and individual sauce containers rather than the main tableware.
Butcher Shops & Food Retail
At service counters, the refill requirement from 2027 is the key issue: customers must be allowed to have their own containers filled with sausages, meat or salads without paying an additional charge. Food hygiene considerations explicitly remain at your discretion – in practice, a tare function on the scales and a clearly defined process can make handling customer containers straightforward.
What to check: Do your scales have a tare function, and is it integrated into your checkout system? Without it, every refill becomes a calculation exercise.
Care & Healthcare Facilities
Providing meals on wards is legally comparable to a canteen – the food is consumed within the facility. Where single-use plastic tableware is used for hygiene or staffing reasons, an alternative will be required by 2030. Fibre-based meal trays are often the most pragmatic option here because they do not require changes to existing hygiene procedures.
What to check: Are there areas where single-use products are necessary for compelling reasons? If so, switch to fibre-based systems early rather than relying on the possibility of an exemption.
What Will It Cost – and Where Does It Pay Off?
The straightforward answer is: changing the material is rarely the expensive part. Fibre-based packaging is generally priced within a similar range to plastic-coated alternatives, and in some cases it costs less. The transition becomes expensive where processes need to be changed – washing capacity, returns and staffing.
Three factors are therefore worth considering in your own calculations:
- Share of revenue from on-site consumption. This determines how much of your business will be affected by the requirements from 2030. Below ten percent, the transition is a relatively minor issue; above one third, it becomes a project in its own right.
- Number of servings per day. From around 150 to 200 servings per day, an in-house reusable system can typically pay for itself within a season compared with the ongoing cost of single-use packaging.
- Number of products in your packaging range. If you currently stock eighteen different cup and container sizes, you may save more by streamlining your range than by changing materials.
What You Can Do in the Next Few Weeks
You do not need to overhaul everything. Start with an inventory. It takes about an hour and will make every subsequent decision easier:
- List your packaging products and indicate whether each one is used for on-site consumption or takeaway.
- Note the material next to each product – and for cups and containers, explicitly record the coating, not just the base material.
- Request the declaration of conformity for your ten highest-selling products from your supplier and store the documents digitally.
- Mark every row where “on-site” and “plastic” appear together. These are exactly the products that will need an alternative by 2030.
Relevant Product Categories in Our Range
- Suitable for on-site consumption from 2030: Paper cups, snack trays and packaging for chips and currywurst
- For takeaway cold drinks with recycled content: rPET cups
- For delivery and collection: takeaway packaging, fast food and street food packaging and soup containers
- Browse by type of business: our industry pages
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