PPWR 07 – Which Packaging Will I No Longer Be Able to Use?

●	The Annex V restrictions apply from 1 January 2030, not from 12 August 2026.
●	PPWR does not ban single-use plastic packaging in general. Annex V contains exactly six restricted categories - full stop.
●	What matters isn’t just the material, but the combination of format + application. The same PET punnet can remain perfectly legal in one use and restricted in another.
●	For fresh fruit and vegetables, there’s a threshold of under 1.5 kg, but also an exemption mechanism - not an automatic ban on every package below that weight.
●	In HoReCa, on-premises consumption and takeaway are not treated the same way. That difference matters enormously for what is actually restricted.
●	A compostable, biodegradable or bio-based material is not automatically exempt from these restrictions.
●	Companies don’t need to wait for 2030. Mapping the packaging portfolio against applications and customers can start now.

A plastics packaging producer supplies, among other things, PET punnets, PP food containers, small PE sachets, hotel shampoo bottles, and shrink film for grouping products.

A customer calls and asks directly: "Will we still be able to buy this packaging from you after 2030?"

The quick answer would be: "Yes, if it complies with PPWR."

But that answer is incomplete.

Because a package can be fully recyclable, contain exactly the right percentage of recycled content, be minimised down to the gram - and still run into a restriction under Article 25 and Annex V of PPWR, for a specific use.

This is where the central distinction of this article comes in: the question isn't just "what is this packaging made of?", but "what format is it, what is it used for, and does that combination fall within Annex V?"

What does Article 25 actually say?

Without the long legal text: from 1 January 2030, economic operators may no longer place on the market packaging in the formats and for the uses listed in Annex V.

That's it.

It is not a general ban on single-use plastic. It is a closed list, with six precise categories. Any packaging that doesn't fall within one of these six categories is not covered by Article 25 - no matter how used we've become to hearing the phrase "PPWR bans single-use plastic."

The six categories under Annex V

1. Grouped packaging at the point of sale

What is restricted: single-use plastic packaging used to group products - bottles, cans, jars, tins, packets - specifically to encourage buying more than one product at once.

Practical example: the shrink film that bundles six beverage cans into a promotional multipack on the shelf.

The important nuance: the Regulation explicitly excludes grouping that is necessary for handling. There's a real difference between film that "tempts you to buy more" and packaging that holds products together for transport and logistics. Not every grouping film automatically falls under this restriction.

Who should pay attention: film manufacturers, brand owners designing promotional multipacks, retailers.

2. Fresh fruit and vegetables under 1.5 kg

What is restricted: single-use plastic packaging for pre-packed fresh fruit and vegetables, below the 1.5 kg threshold.

This is where precision really matters. It isn't a blanket rule along the lines of "any fruit or vegetable under 1.5 kg must be sold without plastic." The Regulation provides for an exemption mechanism covering situations such as water loss, loss of turgidity, microbiological hazards, physical shocks, oxidation, or other forms of deterioration relevant to preventing food waste, where these are legally provided for.

The European Commission must publish relevant guidance by 12 February 2027.

What does that mean in practice? That statements like "500 g tomatoes will be banned" or "blueberries won't be allowed in plastic anymore" are premature. The exemption framework is still taking shape, and fragile products - berries, for instance - have real technical grounds (shock protection, preventing moisture loss) that could support an exemption. Hardier vegetables, such as potatoes or onions, have a weaker case on the same logic, but there's no official list yet either way.

Who should pay attention: fresh-produce packers, retailers, growers' cooperatives, importers of pre-packed produce.

3. HoReCa food and beverage packaging for on-premises consumption

What is restricted: relevant single-use plastic packaging for food and beverages filled and consumed within the premises of HoReCa establishments (hotels, restaurants, catering).

Practical example: a disposable plate, cup or container used for a customer eating at a table, on-site.

The essential nuance - and probably the most widely misunderstood point in this whole article: on-premises consumption and takeaway are NOT treated the same way. The restriction targets the situation where the product is filled and consumed inside the establishment itself. A restaurant essentially has to ask itself: where will the customer actually consume this?

Who should pay attention: restaurants, cafés, canteens, catering operators.

4. Individual portions in HoReCa

What is restricted: single-use plastic packaging for individual portions of condiments, jams, preserves, sauces, coffee creamer, sugar and seasoning, offered in the HoReCa sector.

Practical example: an individual ketchup sachet served with a meal at a table.

The important exception: the Regulation explicitly provides for an exception for individual portions supplied together with ready-prepared takeaway food intended for immediate consumption. In other words, the ketchup sachet that comes with a ready-to-eat takeaway order can be treated differently from the portion served at a table on the premises.

The practical message: the ketchup sachet isn't simply "banned everywhere." Its legal status depends on where and how it is supplied.

Who should pay attention: HoReCa operators, manufacturers of sachets and individual-portion packaging.

5. Accommodation packaging - cosmetics and toiletries

What is restricted: individual single-use packaging for cosmetic, hygiene and toiletry products, associated with an individual booking and intended to be discarded before the next guest arrives.

Practical example: the small shampoo bottle, body lotion, or individually wrapped soap in a hotel room.

A common mistake to watch for: there is no general 50 ml threshold in PPWR for these products. The Regulation doesn't talk about size - it talks about the usage logic: an individual package, tied to a booking, discarded before the next guest.

PPWR also does not require hotels to install wall-mounted dispensers. Refillable dispensers are one possible operational response - not a legal requirement stated as such.

Who should pay attention: hotels, guesthouses, manufacturers and suppliers of cosmetics/toiletries for the hospitality industry.

6. Very lightweight plastic carrier bags

What is restricted: plastic carrier bags with a wall thickness below 15 microns.

Practical example: the thin roll bag at the fruit and vegetable counter in a supermarket.

The relevant exemptions: hygiene needs, and use as primary packaging for loose food where this helps prevent food waste.

Not every thin produce bag automatically disappears from the market - but a very lightweight bag used with no connection to hygiene or food-waste prevention has a much weaker exemption case.

Who should pay attention: retailers, especially those with fresh-produce counters, and bag manufacturers.

"Simple - we'll switch to paper"

This is the natural instinct for many companies: if a plastic format is restricted, replace it with paper or board.

It isn't quite that simple.

First, a replacement package still has to satisfy every other applicable PPWR requirement - minimisation, recyclability, functional requirements, food safety, logistics requirements, plus any other applicable legislation. Solving an Article 25 problem doesn't automatically mean the replacement packaging is compliant everywhere else.

Second - and this is where an important clarification from the European Commission's guidance, C/2026/3702, comes in - for categories 1 to 4 of Annex V, composite packaging containing 5% or more plastic still falls within the relevant restriction. Only packaging with no more than 5% plastic by weight falls outside these specific restrictions.

The practical message: a "paper package" isn't automatically outside Annex V. What matters is its actual composition, not how it's described in marketing. A paper cup with a plastic layer inside may or may not remain within the restriction, depending on the actual percentage of plastic in the packaging's total weight - and that percentage has to be calculated from the real composition, not assumed.

"Then we'll make it compostable"

This isn't straightforward either.

The fact that a plastic is bio-based, biodegradable, compostable - PLA, PHA, or any other bioplastic - does not automatically remove it from the scope of the relevant Annex V restrictions.

"Compostable" doesn't automatically mean "exempt."

A compostable container used for on-premises consumption in a HoReCa establishment remains, from the perspective of Category 3, the same problem as a conventional plastic container, if the format and use match the restriction. Compostability is a property of the material at end of life - not a legal ground for exemption from Article 25.

The real problem for a plastics converter

This is the idea that matters most for Plastinfo readers.

A converter can manufacture a perfectly legal PET punnet as an industrial product. The risk doesn't necessarily come from the product itself.

The risk comes from the fact that a major customer might use that exact punnet in precisely the application that becomes restricted - for example, for berries under 1.5 kg, with no applicable exemption.

Which is why the useful mapping for a packaging manufacturer isn't "what products do we make," but a much more concrete chain:

product → customer → application → country → Annex V exposure.

This map is commercially far more valuable than any generic list of "banned products," for the simple reason that the same product can appear on the map multiple times, with different answers, depending on each customer and each application.

What should I ask the customer, starting now?

A converter doesn't need to wait until 2029 to start asking the right questions:

• What product will be packed?
• What is the proposed pack weight?
• Is it a fresh or a processed product?
• Where will the packaging actually be used - which country, what context?
• Is it consumed on-premises or taken away?
• Is the customer relying on a specific exemption?
• Is the packaging single-use, or part of a genuine reuse system?
• Has an alternative already been tested?

These questions shift the conversation from "what material are we using" to "what exactly is this packaging used for" - and help avoid a converter unknowingly producing exactly the format a customer will no longer be able to use after 2030.

A few concrete cases

500 g tomatoes in a plastic tray. Below the 1.5 kg threshold - worth checking whether there's a technical justification (shock protection, preventing deterioration) that could support an exemption, once guidance becomes available.

PET punnet for berries. High fragility profile - a plausible exemption candidate, but it still needs to be documented, not assumed.

PP food container in a restaurant, served at the table. Falls directly within Category 3 - on-premises consumption.

The same PP container, ordered as takeaway. A different situation - consumption doesn't happen on the premises, which changes the analysis compared to the case above.

Ketchup sachet served at the table in a restaurant. Category 4, without the takeaway exception.

Miniature shampoo bottle in a hotel. Category 5 - regardless of material, because the restriction's logic is about use (tied to a booking, discarded before the next guest), not just about plastic.

Very thin bag for loose vegetables in a supermarket. Below 15 microns - worth checking whether the use supports the hygiene or food-waste-prevention exemption.

Paper cup with a polymer coating inside. Worth checking the actual plastic percentage by weight - under 5%, possibly outside the restriction; above it, still within scope.

Compostable PLA container, used for on-premises consumption. Compostability doesn't change the analysis - if the format and use match Category 3, the restriction still applies.

Shrink film grouping six bottles on the shelf. Worth checking whether the grouping serves a promotional purchase incentive or is necessary for handling - the difference matters legally.

Who should be paying close attention to this?

The plastics converter - needs to know what applications its products actually end up in, not just what products it makes.

The fresh-produce packer - has direct exposure for any format under 1.5 kg without a clear exemption.

The HoReCa operator - needs to clearly separate, operationally, packaging for on-premises consumption from packaging for takeaway.

The hotel - needs to know whether its current toiletries fit the "tied to a booking, discarded before the next guest" logic.

The retailer - is exposed both for fresh produce and for very lightweight bags at its own counters.

The brand owner - is responsible for any restricted format sold under its own brand, regardless of who physically manufactured it.

The packaging distributor - needs to understand the final application of the formats it distributes, not just the technical specifications.

What can I do now?

WHAT I CAN DO NOW

• take stock of the single-use plastic packaging I produce or use;
• map each product to its actual end-use application, not just its material;
• identify exposure to the six Annex V categories;
• identify the customer and country for each exposed format;
• start conversations with customers using the questions above;
• estimate what share of revenue is exposed to these restrictions.

WHAT I'M PREPARING NOW, TO IMPLEMENT AFTER VALIDATION

• alternative formats for clearly exposed applications;
• reuse or refill options, where commercially sensible;
• customer trials for new variants;
• material alternatives, where genuinely justified;
• any necessary equipment modifications.

WHAT I'M TRACKING

• the European Commission's guidance on fresh fruit and vegetables, expected by 12 February 2027;
• any exemption lists published by Member States;
• any further Commission guidance on Annex V;
• any amendments to Annex V;
• relevant national measures, where they exist.

WHAT I WOULDN'T DO YET

• I wouldn't automatically replace every plastic package with paper, without checking the actual composition and every other applicable PPWR requirement;
• I wouldn't assume a compostable material is automatically exempt;
• I wouldn't drop an entire product family without analysing the applications it actually covers;
• I wouldn't assume the same answer applies identically across every EU country.

A few common misunderstandings

"PPWR bans single-use plastic from 2030."
False. Exactly six specific categories of formats and uses are restricted - not single-use plastic in general.

"All fruit and vegetables under 1.5 kg will no longer be allowed in plastic."
Needs qualification. The threshold exists, but so does the exemption mechanism - still being clarified.

"On-premises consumption and takeaway are treated the same."
False. That difference is central to Categories 3 and 4.

"Paper is automatically safe from a PPWR standpoint."
False. What matters is the actual composition, including the percentage of plastic by weight.

"Compostable plastic is exempt."
False. Compostability, by itself, is not a ground for exemption from Article 25.

"Hotel toiletries under 50 ml are banned."
False. There is no general 50 ml threshold in PPWR for this category.

"If I manufacture the packaging, I'm the only one who needs to worry."
False. Responsibility is distributed along the chain - from manufacturer to packer, brand owner, HoReCa operator or hotel.

"If the product isn't banned, I have no problem."
False. The application can be restricted even when the product itself remains perfectly legal in another context.

How this connects to the rest of the series

PPWR 04 asked: can this packaging actually be recycled?

PPWR 05 asked: how much recycled content will it need to contain?

PPWR 06 asked: am I using more packaging than necessary?

PPWR 07 adds a new question, independent of the other three:

Am I still allowed to use this format, for this application, after 2030?

A package can answer the first three questions perfectly - recyclable, with the right recycled content, properly minimised - and still run into a restriction under Article 25. That's why PPWR compliance has to be looked at as a system, not as four independent requirements ticked off one by one.

The real question

Don't just ask: "Will this plastic product still be legal?"

Ask: "Which of my customers will still be able to use this format, for which applications, and in which markets?"

That, in effect, is the practical conclusion of PPWR 07. Mapping product → application → customer → market isn't a bureaucratic exercise. It's exactly the information you need to know, today, which part of your portfolio genuinely deserves attention before 2030.

The PPWR series keeps developing based on the questions we receive from industry. If you manufacture or use a format that you think might fall within one of the six categories above, and you're not sure exactly how it applies to your situation - write to us. Questions like that often become the next topic in this series.

OFFICIAL SOURCES

• Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste - in particular Article 25 and Annex V.
• European Commission – Guidance document for Regulation (EU) 2025/40, C(2026) 3702.
• Directive (EU) 2019/904 on the reduction of the impact of certain plastic products on the environment (the Single-Use Plastics Directive), in connection with the relevant PPWR provisions.

CONTEXT SOURCES

• European Commission – Packaging and Packaging Waste Regulation (PPWR).