PPWR: What the New EU Packaging Regulation Means for Caterers

What the PPWR is — and why it is different from the Packaging Act

PPWR stands for Packaging and Packaging Waste Regulation, officially Regulation (EU) 2025/40. It came into force on 11 February 2025 and has been applicable since 12 August 2026. It replaces the old EU Packaging Directive from 1994.

The crucial difference lies in the word: The predecessor was a directive — it first had to be transposed into national law, in Germany into the Packaging Act (VerpackG). The PPWR is a regulation and applies directly in all member states, without intermediary steps and in the same wording in every country.

Germany therefore replaced the VerpackG: The Packaging Law Implementation Act (VerpackDG) was published in the Federal Law Gazette on 17 July 2026 and has been in effect since 12 August 2026. It now only regulates what the EU leaves to the member states — competences, registration duties and sanctions. The familiar structures remain: the Central Agency Packaging Register (ZSVR) and the register LUCID still exist, as well as participation in a dual system. New are the fines: violations can be sanctioned with up to 200,000 euros.

Who does it apply to? Everyone who places packaging on the market or fills packaging — from the manufacturer, through the retailer, to the caterer who packs food for takeaway. A restaurant without takeaway business is not affected by the reuse obligations, but very much by the material requirements for the purchased packaging material.

The schedule at a glance

The PPWR is not a rule but a phased plan until 2040. These dates concern gastronomy:

Memorandum: 2026 mainly changes what can be in the material. 2027 and 2028 change how you serve. 2030 changes what is available at all.

What has actually applied since 12 August 2026

PFAS limits for all food contact materials. For the first time, there are EU-wide binding limits for per- and polyfluorinated alkyl substances in packaging that touch food. Article 5 paragraph 5 specifies 25 ppb per individual substance, 250 ppb for the sum of PFAS and 50 mg/kg total fluorine. It does not matter whether the substances were intentionally added or are present as contaminants.

In practice, this affects exactly the items frequently used in take-away: greaseproof papers, coated fries cartons, burger paper, baking paper, pizza boxes with grease barriers. PFAS have been the means of choice against grease penetration there for decades. The proof obligation lies with the marketer, i.e. the manufacturer or importer — not with the caterer. Your task is different: to obtain confirmation of conformity from the supplier.

Coffee capsules, pods and tea bags are now packaging. Previously, it was inconsistently regulated across Europe whether these wrappers belong to the product or the packaging. Since 12 August 2026, they are clearly classified as packaging — with all reporting and licensing consequences for those who place them on the market. For the business that only uses them, nothing changes in their use. Important against the headlines: There is no ban on capsules, pods or tea bags as of 12 August 2026, and no deposit has been introduced on them.

Registration and proof. Anyone placing packaging on the market remains subject to notification in the LUCID register and must report quantities annually. New is the closer look at roles: who is legally the "producer" depends on who first places the packaging on the market — for own brands and imports from third countries this can be the business itself sooner than one thinks.

2027 and 2028: Reuse becomes mandatory — with a pricing rule

This is the part that restructures everyday business.

From 12 February 2027, businesses providing hot or cold drinks or ready-prepared meals for takeaway must provide a system allowing guests to fill their own container. No extra charge may be applied.

From 12 February 2028, the second phase applies: additionally, a reuse alternative must be offered — and this must not be more expensive than the single-use version. This removes the lever with which reuse was previously made unattractive by pricing.

Those operating in Germany already know part of this: the reuse obligation has been in German law since 2023. The PPWR extends this line EU-wide and supplements it with the obligation to fill brought containers. Exceptions are provided for small businesses; how these are specifically tailored in Germany is clarified by the VerpackDG or the competent authority — this is where looking at your own business size and a phone call to the Chamber of Industry and Commerce is more useful than any rule of thumb.

What this means hygienically

A brought container is a foreign object in your kitchen. The recommended approach, also advised by health authorities, is: The container is not passed into the kitchen area, but placed at a defined handover point and filled there; staff only touch the rim from the outside; visibly dirty containers may be refused. Document this in writing in your HACCP plan before the obligation takes effect — then at the next inspection there is a procedure in your files and no improvisation.

2030: What disappears from the range

Most false reports circulate here. The format bans from Annex V do not apply from August 2026 but only from 1 January 2030. Until then there is time — but the direction is set, and anyone procuring dishware in 2028 should be aware.

For hotels this means specifically: dispensers instead of bottles in the bathroom. For gastronomy: refillable dispensers or reusable bowls instead of ketchup sachets and plastic sugar sticks. And in the buffet sector an early look at containers designed for frequent washing is worthwhile.

Also from 2030: graduated minimum shares of post-consumer recycled material in plastic packaging — depending on packaging type between 10 and 35 percent. And for shipping packaging a maximum empty space quota of 50 percent applies; cushioning material counts as empty space, not goods. This affects everyone who ships themselves — from farm shop to caterer with online shop.

What this means for the kitchen — the four practical consequences

1. More washing volume. This is the biggest and most frequently underestimated consequence. Every reusable cup, reusable bowl and portion container replacing a single-use packaging ends up in the washing kitchen afterwards. Anyone working at capacity today will not manage with reuse during peak times. The most honest test: count how many single-use items you serve in one week — exactly this amount must the washing kitchen handle additionally.

2. More circulation, i.e. more inventory. Reuse requires multiple times the amount issued, because part is with the guest, part returned, and part in washing. As a practical guideline: two to three times what you serve on a peak day.

3. More storage space and a return point. Clean containers need shelving; returned ones need a separate, easily cleanable space in front of the dishwasher. This is the actual bottleneck with existing layouts — more often than the machine itself.

4. Different waste logic. If less single-use waste arises, waste streams shift. Less residual waste, but more food scraps and more cleaning effort. Separate containers in the right place save more time than their purchase costs.

Five steps that make sense now

1. Inventory packaging. List what you buy: material, supplier, purpose, annual quantity. Without this list, none of the following questions can be answered.

2. Obtain written confirmation of conformity. Ask every supplier of packaging with food contact to confirm compliance with PPWR PFAS and heavy metal limits. An email is enough — but get it before an inspection asks for it.

3. Check LUCID registration and quantity reports. Are registration, roles and reported quantities still correct? This is where fines actually become due.

4. Calculate washing capacity honestly. Not based on the catalogue value "baskets per hour", but on your peak hour. If it barely suffices today, it won’t with reuse.

5. Define the handover point for brought containers — spatially and in the HACCP concept. It costs nothing and saves stress in 2027.

Frequently asked questions about the PPWR

Suitable devices at Gastro-Nik

The PPWR shifts work from packaging to the washing kitchen. These devices catch that:

Washing capacity for the reuse circulation:

• Glass dishwasher Ready 405 | KBS — for cups and glasses at counters
• Dishwasher Ready 505 AP | KBS — undercounter unit with drain pump
• Hood dishwasher Ready 605 | KBS — when reuse carries the peak time

Save rework — items come dry and polished from the cycle:

• Glass polisher SV1000 | Frucosol — 240–360 glasses per hour without towel
• Cutlery polisher SH3000 | Frucosol — 3,000–3,500 cutlery items per hour, with UV sterilisation
• Glass rack 500×500 mm for 25 glasses | Virtus

Transport and retrieval of reusable items:

• Thermobox neutral, 6× GN 1/1 | Virtus — food in reusable containers instead of single-use bowls
• Heated thermobox on wheels, 7× GN 2/1 | Virtus — for catering and delivery routes
• Stainless steel waste bin on wheels with foot operation, 50 L | Virtus — for separate collection at the return station

Browse further: Glass dishwashers · Dishwashers · Cutlery polishers · Glass polishers · Transport & service carts · Waste containers

Status: 13 August 2026. This overview summarises the legal status under Regulation (EU) 2025/40 and the Packaging Law Implementation Act. It does not replace legal advice — for binding classification of your business, the competent authority, your Chamber of Industry and Commerce or a specialised lawyer are the appropriate contacts.