31/07/2025

The new EU Packaging and Packaging Waste Regulation (PPWR) aims to drastically reduce packaging waste across the European Union and promote the transition to a circular economy. It becomes legally binding on 12 August 2026, with individual provisions entering into force gradually. These include specific requirements for recyclability and reuse.

Food retailers, restaurateurs, and providers of take-away or delivery services, in particular, must prepare for new obligations relating to reusable packaging and return systems.

What does the new EU packaging regulation (PPWR) cover?

The new PPWR – officially Regulation (EU) 2025/40 – replaces Directive 94/62/EC and introduces, for the first time, directly applicable legal standards for all EU Member States.

The regulation applies to all packaging and packaging waste generated within the EU, across all sectors and in both B2C and B2B contexts. It focuses on design, materials used, and disposal processes.

Key elements include:

Binding recyclability standards and labeling obligations
Reuse and refill requirements for selected product categories
Extended producer responsibility (EPR): obligations for traceability, reporting, and declarations of conformity

What is EPR (extended producer responsibility)?

Extended producer responsibility (EPR) requires businesses that place packaging on the market to assume responsibility for its entire lifecycle – from design and use to final disposal. Obligations include registration with national systems, volume reporting, financing of disposal processes, and proof of recyclability. The goal is to fairly distribute disposal costs and incentivize eco-friendly packaging design.

What is the purpose of the regulation?

The EU sees this regulation as a key tool for tackling pollution, resource waste, and climate change. Packaging constitutes a significant portion of municipal waste and is often used only once before being discarded – frequently without material recycling. This linear model contributes significantly to CO₂ emissions and ecological degradation. The PPWR is designed to reverse this trend by reducing material usage, boosting recycling rates, and promoting a genuine circular economy.

Key 2040 targets include:

Reducing packaging waste per capita by 15% (compared to 2018)
Ensuring all packaging is recyclable (Grades A to C) by 2030
Introducing mandatory reuse/refill quotas for sectors such as HORECA (Hotels, Restaurants, Cafés)

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When does PPWR apply – and how will it be implemented?

Adopted by the EU Council on 16 December 2024, the PPWR entered into force on 11 February 2025. It becomes legally binding for businesses on 12 August 2026. As a regulation, it applies directly across all Member States, without requiring transposition into national law. National packaging laws – such as Germany’s Verpackungsgesetz or France’s Loi AGEC – must be adapted or repealed. Businesses must now align directly with EU rules. Provisions like the reuse obligations in gastronomy or bans on specific single-use packaging will roll out gradually until 2030.

Who is affected by the PPWR – and what are their obligations?

The PPWR affects all businesses along the supply chain: packaging producers, brand owners, retailers, and food service providers. Responsibility lies primarily with those placing packaging on the market – producers and importers – who must ensure conformity, traceability, and recyclability. Other stakeholders – such as logistics providers, retailers, and the HORECA sector – must meet strict requirements around packaging selection, labeling, and return systems.

Who must comply: An overview of food retail, HORECA, and food services

Any business that packages, sells, or distributes food is subject to PPWR obligations, especially if single-use packaging is involved. This includes:

Food retailers and supermarkets (brick-and-mortar & online)
HORECA establishments (hotels, restaurants, cafés)
Catering and event food services
Delivery and take-away providers
Wholesale and intermediary traders with packaging duties
Retail food services (e.g. bakeries with seating areas, supermarkets with food counters)

In short: any actor in the food value chain using or distributing packaging, or offering food-related services involving packaging, falls under the PPWR.

How does the PPWR affect food retailers?

Food retailers are particularly affected, given the high volume of packaging they place on the market – both for fresh and processed goods. They play a central role in implementing the new requirements.

Scope: Sales packaging

Retail food packaging – such as pre-packaged salads or takeaway items – falls entirely under PPWR rules, in both B2C and B2B contexts.

Mandatory reuse/refill options

By February 2028, retailers must offer reusable or refillable alternatives for takeaway food and beverages.

Recyclability and labeling requirements

All packaging must be recyclable and clearly labeled with material identification and disposal instructions – either on the packaging itself or within barcodes (e.g. EAN labels).

EPR: Registration and compliance proof

Retailers must register their packaging volumes, report them, and provide documentation proving compliance and recyclability under EPR rules.

Avoiding unnecessary packaging

The regulation demands the elimination of superfluous packaging – such as secondary wraps or double plastic protection – to save resources and reduce waste.

How does the PPWR affect restaurant owners and caterers?

Gastronomic operations – fixed or mobile – are also a key focus of the new regulation. PPWR explicitly targets the HORECA sector, (hotels, restaurants, cafés) while also covering canteens, takeaway shops, and hybrid formats like bakeries with seating or supermarkets offering hot food. This means that the regulation applies to both traditional restaurants and retailers offering food services.

Mandatory reuse for takeaway

From 12 February 2028, food service providers must offer reusable options for takeaway drinks and ready-to-eat meals.

At least 10% of sold units must be served in reusable packaging by 2030
Customers must be actively and clearly informed of reusable options – at no surcharge compared to single-use alternatives

Ban on certain single-use materials

From 1 January 2030, some packaging types – such as certain PET containers, polystyrene, or coated plastics – will be banned due to their environmental and recycling drawbacks.

Documentation and traceability requirements

Operators must keep records demonstrating packaging compliance – especially regarding reusable packaging and transport containers (e.g. crates, pallets).

EPR obligations for food services

Gastronomers who sell packaged food or beverages are classified as "first distributors" and fall under EPR obligations. This includes registration, return systems, labeling, and regular reporting – to ensure full traceability and circular use.

What opportunities does the PPWR offer, and how can companies benefit from it?

While the PPWR poses challenges for B2B companies, it also opens up opportunities: businesses that invest early in circular packaging solutions can position themselves as sustainable brands – an increasingly decisive factor for both consumers and B2B clients. Reusable systems can enhance customer loyalty by appealing to environmentally conscious target groups. Incentives for returns, deposit schemes, or loyalty programs may encourage repeat purchases. However, rolling out such systems requires clear communication and customer engagement, as disposables are often seen as more convenient.

The key lies in a strategic early review of packaging portfolios, collaboration with suppliers, and effective brand messaging. Companies that see the regulation not just as an obligation, but as an opportunity for innovation and competitive differentiation, will be best positioned to thrive.

Sources: Packaging Ordinance PPWR in the Official Journal, EXPRA Newsletter, Zero Waste Europe, Europen Survival Guide

Portrait of Julia Pott, member of the EuroShop editorial team, with shoulder-length brown hair, hoodie and open smile; copyright: beta-web GmbH

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Author: Julia Pott | EuroShop.mag

Julia Pott has been working as an editor in the retail sector for eight years – initially at the retail magazine iXtenso, at times also as editor-in-chief. Today, she is responsible for the concept, editorial plan, content and design of the online magazine EuroShop.mag on behalf of the EuroShop and EuroCIS trade fairs. Her contributions combine editorial depth with a feel for trends and topics that drive the retail sector.