PPWR for Hospitality & Take-away: What Applies from 12.08.2026
Restaurants, cafés and take-away businesses are among the sectors most heavily affected by the new EU Packaging Regulation (EU) 2025/40 (PPWR). In addition to the single-use plastics ban already in force under the SUP Directive, far-reaching new obligations will apply from 12 August 2026 – from recyclability requirements and labelling obligations to a mandatory reusable packaging offer. Acting now avoids costly last-minute conversions under time pressure.
The SUP Ban: What Already Applies
Since 2021, the EU Single-Use Plastics Directive (SUP) has been transposed into national law. For your business, this means: single-use plates and cutlery made of plastic, drinking straws, stirrers, and cups and containers made of expanded polystyrene are already prohibited. Products made of oxo-degradable plastic are subject to a general marketing ban. Check whether any remaining stock of such products is still stored in your kitchen or service area – their sale is no longer permitted.
PPWR from 12.08.2026: The New Core Requirements
Regulation (EU) 2025/40 builds on the SUP Directive and structurally tightens the requirements. The following points are central for your food service operation:
- Recyclability of all packaging: Coffee cup lids, to-go boxes, salad containers and snack packaging must be recyclable from the cut-off date onwards. Composite materials that cannot be separated must be phased out progressively.
- Labelling obligation: Every packaging unit must clearly display the material and information on correct disposal. Use the transition period to adjust your supplier contracts accordingly.
- Minimum recycled content: Graduated minimum proportions of recycled material apply to plastic packaging. When purchasing goods, verify that your packaging supplier provides the corresponding conformity documentation.
Since 2023, Germany's mandatory reuse requirement under Section 33 of the Packaging Act (VerpackG) has applied to businesses with 5 or more employees and a sales area of 80 m² or more. The PPWR requirements reinforce this trend at EU level. Specifically relevant for you:
Businesses with 25 or more seats (indoor and outdoor combined) are required to offer food and beverages in reusable containers upon the customer's request – either through an in-house reuse system or via recognised pool systems such as Relevo, Recup or Vytal. The reusable product must not be more expensive than its single-use equivalent.
Practical recommendation: Evaluate pool system partnerships at an early stage. System fees are manageable, and many municipalities actively support the transition.
Operational Compliance Checklist
1. Identify and remove remaining SUP stock 2. Check all active packaging products for recyclability (request supplier documentation) 3. Ensure labelling compliance of all to-go packaging 4. Determine seating capacity and clarify the mandatory reusable packaging offer obligation 5. Obtain recycled content documentation for plastic packaging throughout the supply chain 6. Train staff: reusable dispensing process, returns, cleaning
Important note: The legal requirements are complex and depend in detail on your business size, product range and corporate structure. For a legally sound assessment of your individual obligations, contact your regional Chamber of Commerce (IHK) – they provide free initial consultations and up-to-date guidance on the national implementation of the PPWR.
Häufige Fragen
- From when does the mandatory reusable packaging offer apply to my business?
- In Germany, the obligation to offer reusable alternatives for food and beverages to take away has applied since 1 January 2023 for businesses with 5 or more employees and a sales area of 80 m² or more. For businesses with 25 or more seats (indoor and outdoor), an additional obligation applies to offer reusable containers for on-site consumption upon customer request. The PPWR (EU) 2025/40 makes these requirements binding across the EU from 12.08.2026.
- May I continue to use single-use paper coffee cups?
- Paper cups without plastic lining are generally still permitted, provided they are recyclable and correctly labelled. However, most commercially available single-use coffee cups have a thin PE inner coating that limits recyclability. From 12.08.2026, you must be able to demonstrate that the cups you use meet the PPWR's recyclability requirements. Request the relevant conformity documentation from your packaging supplier.
- What happens if I do not comply with the labelling obligations?
- Violations of the PPWR's labelling and recyclability requirements may be sanctioned as administrative offences under national implementing legislation. The specific fine ranges will be set out in national implementing law. In addition, competitors or consumer protection associations may issue cease-and-desist notices under competition law. Early transition is therefore economically more prudent than reactive action after the legislation comes into force.
- Is it sufficient to offer just one reuse system, or do I need to provide multiple options?
- The law does not prescribe how many reuse systems you must offer – a single system (in-house or pool-based) is sufficient. The decisive factor is that the reusable option is genuinely available when the customer requests it and that it is not priced higher than the single-use alternative. Pool systems such as Recup, Relevo or Vytal have the advantage that customers can return their containers at many locations, which significantly increases acceptance.
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