PPWR for Food & Beverages: What Manufacturers and Fillers Need to Know from 12 August 2026

Food Contact Materials (FCM) and PPWR – a Dual Obligation

Packaging that comes into direct contact with food is subject simultaneously to the PPWR and the EU Food Contact Materials Regulation (EC) 1935/2004. This means for you: every recycled content share in a primary packaging – i.e. in direct product contact – must demonstrably comply with food contact requirements. Not every recycled plastic meets this requirement. Obtain written declarations of compliance from your recyclate suppliers confirming FCM conformity pursuant to Article 16 of Regulation (EC) 1935/2004 before using recycled content.

Recycled Content Obligations for Plastic Packaging

From 12 August 2026, graduated minimum shares of post-consumer recyclate (PCR) in plastic packaging will apply. For single-use plastic beverage bottles, the first threshold is 30 % (PET bottles over 3 litres: 10 %). Food manufacturers using plastic trays, film packaging or pouches are also subject to the PCR quota once the packaging falls into the relevant category. Document the origin of recyclate without gaps – the competent market surveillance authority may request evidence.

Labelling Obligations: Allergens, Shelf Life and QR Code

The PPWR introduces a digital product passport for packaging on a phased basis from 2028. For food business operators, this means: plan your label layout and data structure now so that a QR code can be integrated without displacing the mandatory information required under the FIC Regulation (allergens, best-before/use-by date, nutritional values). Particularly for fresh products with small label areas – yoghurt pots, individual cheese portions, convenience trays – space management becomes a genuine challenge. Test early whether your print service providers can integrate QR code-capable print layouts into the existing production process.

Cold Chain Labelling and Short Shelf Life

For chilled and frozen products, labels must remain legible and adherent even under condensation moisture and cold – this is not a new obligation, but the PPWR labelling elements (recyclability label, recycled content indication) are now added. Use only adhesives and printing inks certified for the refrigerated range. Otherwise labels are non-compliant, even if the content is correct.

Reusable Packaging Obligation for Beverage Packaging from 2030

From 2030, beverage manufacturers in defined categories (water, soft drinks, beer, wine below certain thresholds) must offer reusable options. Plan now whether to switch to reusable systems or enter into cooperation agreements with deposit system operators. Early investment pays off: those who begin with pilots in 2027 will have smooth operations by 2030.

Practical Immediate Measures

• Conduct a packaging audit: Record all primary, secondary and transport packaging according to PPWR categories.
• Conduct supplier discussions: Request FCM compliance documentation for recycled content shares.
• Start labelling planning: Prepare label layout for QR code integration and new label pictograms (sorting symbol, recycled content share).
• Obtain legally sound advice: Contact your local Chamber of Commerce and Industry (IHK) – it offers industry-specific advice on PPWR implementation and can, if necessary, refer you to specialist lawyers in food and packaging law.