What Are Restricted Packaging Formats Under PPWR?

Restricted packaging formats are packaging formats or uses that the PPWR prohibits or restricts because they are considered unnecessary, avoidable, or inconsistent with EU waste prevention and circular economy goals.

The restrictions are mainly focused on certain single-use packaging formats, especially where reusable, refillable, unpackaged, or less wasteful alternatives may be possible.

The workshop explains that certain types of packaging listed in Annex V cannot be placed on the market, and that some packaging formats listed in Point 3 of Annex V are banned starting 1 January 2030. It also notes that Member States may exempt micro-companies from certain restrictions where it is not technically feasible to avoid the banned packaging or switch to a reuse system.

In practical business terms, restricted packaging formats may affect:

• Retail multipacks
• Fresh fruit and vegetable packaging
• HORECA food and beverage packaging
• Single-use condiment portions
• Hotel miniatures and toiletry packaging
• Very lightweight plastic carrier bags
• Certain plastic grouped packaging formats
• Certain composite or other single-use packaging formats

The restrictions should be reviewed at packaging-format level, not only at material level. A company needs to understand what the packaging is used for, where it is used, whether it is single-use, whether it is plastic or composite, and whether any exemption or justification applies.

Why Restricted Packaging Formats Matter for Market Access

Restricted packaging formats matter because they can directly determine whether packaging can continue to be used in the EU market after the relevant deadline.

A product may be compliant from a safety, chemical, labelling, and product performance perspective, but if it is sold in a restricted packaging format, the packaging can create market access risk.

Business risks of restricted packaging formats

The European Commission states that packaging waste is growing faster than economies and population, and describes packaging waste as often unnecessary and burdensome. Restricted packaging format rules are therefore part of a wider PPWR strategy to reduce avoidable packaging and promote better packaging design.

Key Deadline: 1 January 2030

The most important date for restricted packaging formats is 1 January 2030.

The workshop states that from 1 January 2030, there is a ban on placing on the market packaging formats and uses listed in Annex V. It also notes that the European Commission is expected to provide guidelines within 24 months after the regulation’s entry into force, in consultation with Member States and the European Food Safety Authority, to clarify the scope of Annex V.

The official PPWR framework is already in force, and the Commission guidance document confirms that Regulation (EU) 2025/40 entered into force on 11 February 2025 and applies from 12 August 2026.

Practical restricted-format timeline

Companies should not wait until 2030 to start reviewing packaging. For many businesses, especially those with global packaging lines, private-label products, retailer approvals, packaging molds, food-contact packaging, hospitality operations, or supplier contracts, 2030 preparation should start years earlier.

Restricted Packaging Formats at a Glance

The workshop identifies several restricted packaging formats and uses under PPWR Annex V. The following table summarizes the main categories and practical examples.

The workshop also notes that Annex V includes single-use accommodation sector packaging intended for an individual booking and very lightweight plastic carrier bags.

Single-Use Plastic Grouped Packaging

Single-use plastic grouped packaging is one of the key restricted formats.

The workshop defines this category as plastic packaging used at retail level to group goods sold in cans, tins, pots, tubs, and packets, where the packaging is designed as convenience packaging to enable or encourage end users to purchase more than one product. It excludes grouped packaging necessary to facilitate handling in distribution.

Examples

Practical business questions

Companies should review all retail multipack formats and clearly separate packaging used for consumer promotion from packaging used for transport or distribution protection.

Fresh Fruit and Vegetable Packaging

Single-use packaging for fresh fruit and vegetables is another major restricted category.

The workshop states that single-use plastic packaging, single-use composite packaging, or other single-use packaging for less than 1.5 kg of fresh fruit and vegetables is restricted unless there is a demonstrated need to avoid water loss, turgidity loss, microbiological hazards, or physical shocks.

Examples

When packaging may still be justified

The key point is evidence. If a company continues using single-use packaging for fresh produce under 1.5 kg, it should be able to demonstrate why the packaging is necessary.

Practical preparation steps

Companies should:

1- Identify all fresh fruit and vegetable packaging under 1.5 kg.

2- Classify material type and packaging format.

3- Assess whether packaging is necessary for food safety, quality, or damage prevention.

4- Collect supplier and technical evidence.

5- Evaluate unpackaged, reusable, paper-based, or other compliant alternatives.

6- Monitor Commission guidance and Member State implementation.

HORECA Food and Beverage Packaging Consumed on Premises

The HORECA sector includes hotels, restaurants, cafés, catering, and similar food service operations. Under PPWR, certain single-use packaging formats used for foods and beverages consumed on premises are restricted.

The workshop describes this category as single-use plastic, single-use composite, or other single-use packaging for foods and beverages filled and consumed within the premises in the HORECA sector. It includes eating areas inside and outside a place of business, areas with tables and stools, standing areas, and shared eating areas offered by several operators or third parties for food and drink consumption.

Examples

Practical questions for HORECA operators

HORECA businesses should start by mapping where products are consumed: on premises, take-away, delivery, event catering, or mixed-use situations.

Single-Use Condiment and Serving Packaging in HORECA

Single-use condiment and serving packaging is another important restriction area.

The workshop identifies single-use packaging in the HORECA sector containing individual portions or servings used for condiments, preserves, sauces, coffee creamer, sugar, and seasoning. It notes an exception where such packaging is provided together with take-away ready-prepared food intended for immediate consumption without further preparation.

Examples

Practical alternatives to assess

HORECA operators should not assume that all condiment sachets are banned in every situation. The use case matters. However, individual portions for on-premises use should be reviewed as a priority.

Single-Use Hotel Miniature Packaging

Hotel miniature packaging is a high-visibility restricted format because it is commonly used for cosmetics, hygiene, and toiletry products.

The workshop identifies single-use hotel miniature packaging for cosmetics, hygiene, and toiletry products of less than 50 ml for liquid products or less than 100 g for non-liquid products. Examples include shampoo bottles, hand and body lotion bottles, and sachets around miniature bar soap.

Examples

Practical alternatives for hospitality businesses

Hotels and accommodation providers should start by reviewing all in-room amenities, bathroom products, guest kits, spa products, and housekeeping supplies.

Very Lightweight Plastic Carrier Bags

Very lightweight plastic carrier bags are also addressed under PPWR waste prevention rules.

The workshop identifies a ban on very lightweight plastic carrier bags, except where required for hygiene reasons or provided as sales packaging for loose food when this helps prevent food waste. It also notes that Member States may require compostability for lightweight and very lightweight plastic carrier bags on their territories.

The EUR-Lex summary confirms that very lightweight bags are banned unless used for hygiene or to prevent food waste, and that Member States may decide whether very lightweight bags must be compostable in their territories.

Practical examples

Retailers should assess bag use by department, not only at store level. Produce, bakery, meat, fish, delicatessen, pharmacy, and general checkout areas may have different justifications.

Micro-Company Exemptions and Special Cases

The workshop notes that where a small business qualifies as a micro-company under EU rules and it is not technically feasible to avoid the banned packaging or switch to a reuse system, Member States may exempt them from the ban in Point 3 of Annex V.

This exemption should be treated carefully. Companies should not assume that being small automatically creates an exemption. The exemption depends on legal status, technical feasibility, Member State implementation, and the specific packaging format.

Exemption evidence checklist

Exemptions should be documented and reviewed regularly, especially where packaging alternatives become available.

National Restrictions and SUPD Interaction

Companies should also consider the relationship between PPWR restrictions and existing national restrictions under the Single-Use Plastics Directive, known as SUPD.

The workshop explains that SUPD generally prevails over PPWR unless otherwise provided, and that Member States may maintain existing packaging bans related to certain Annex V formats until 1 January 2030. It also notes that PPWR bans apply from 1 January 2030 and that expanded polystyrene food containers, beverage containers, and cups for beverages are already banned under SUPD, with PPWR amendments adding XPS formats after a later application period.

Why this matters

Companies should not assume that 2030 is the first time packaging restrictions matter. In some Member States, national restrictions may already apply.

Composite Packaging and Partial Plastic Content

Composite packaging can create confusion because some packaging contains more than one material.

The workshop explains that composite packaging is a packaging unit made of two or more materials that form part of the main packaging material and cannot be separated manually, unless one material is insignificant and no more than 5% of the total mass, excluding labels, varnishes, paints, inks, adhesives, and lacquers. It also notes that the definition of composite packaging should not exempt single-use packaging partially made of plastic from Single-Use Plastics Directive requirements.

Practical questions for composite packaging

Companies using composite packaging should maintain accurate material breakdowns and avoid assuming that a small plastic fraction automatically removes regulatory risk.

Which Sectors Are Most Affected?

Restricted packaging formats affect multiple sectors, but some are more exposed than others.

High-impact sectors

Companies should identify affected product categories and prioritize high-volume, high-risk, or customer-facing packaging formats.

Practical Alternatives to Restricted Packaging Formats

Companies should start evaluating alternatives early. However, the right alternative depends on product safety, hygiene, logistics, shelf life, consumer use, and waste infrastructure.

Possible alternative strategies

Alternative packaging should be tested before implementation. Companies should assess product protection, consumer acceptance, hygiene, logistics, recyclability, reuse system requirements, labelling, EPR reporting, and cost.

Technical Documentation for Restricted Packaging Formats

Restricted packaging format compliance should be documented. Companies may need to prove that a packaging format is not in scope, that an exemption applies, or that the packaging has been replaced.

The workshop’s technical documentation section explains that companies should maintain packaging descriptions, design and manufacturing details, relevant standards or specifications, evidence of recyclability assessments, and a Declaration of Conformity. It also identifies violations of packaging restrictions as a formal non-compliance risk.

Documentation checklist

A compliance file is especially important where a company continues using a packaging format that may appear restricted but is justified by an exemption or out-of-scope use case.

Packaging Restrictions and EPR Data

Restricted packaging formats also affect EPR and packaging reporting because companies need accurate data on packaging types, materials, weights, and markets.

The workshop identifies producer data categories such as packaging quantities by material and type, composite packaging data, reusable packaging data, annual plastic carrier bag data, deposit-return system data, and packaging placed on market.

Data to collect for restricted packaging formats

Packaging restrictions should be integrated into packaging data management, not handled only as a legal memo.

Common Mistakes Companies Should Avoid

Restricted packaging format risks often happen because companies focus only on material compliance or recyclability and forget packaging use cases.

Common mistakes

A strong packaging restriction review should combine legal assessment, packaging data, product use context, supplier evidence, and technical documentation.

Practical Restricted Packaging Readiness Roadmap

Companies can use the following roadmap to prepare for restricted packaging formats under PPWR.

Step 1: Build a packaging format inventory

List all packaging formats used across products, business units, suppliers, retail channels, HORECA operations, hospitality services, and markets.

Step 2: Identify single-use packaging

Classify whether each packaging format is single-use, reusable, refillable, grouped, transport, service, sales, HORECA, fresh produce, hotel, or carrier bag packaging.

Step 3: Map packaging to Annex V categories

Compare each packaging format against restricted categories such as single-use plastic grouped packaging, fresh produce packaging, HORECA packaging, condiment packaging, hotel miniatures, and very lightweight plastic carrier bags.

Step 4: Assess material composition

Identify whether the packaging is plastic, composite, partially plastic, paper-based, compostable, reusable, or another material.

Step 5: Review use case and location

Determine whether the packaging is used at retail level, for distribution handling, for HORECA on-premises consumption, for take-away, for hotel accommodation, or for fresh produce.

Step 6: Identify exemptions or justifications

Assess whether exemptions may apply, such as hygiene, food waste prevention, microbiological hazard avoidance, physical shock protection, or micro-company status.

Step 7: Prioritize high-risk packaging

Prioritize packaging that is high-volume, customer-facing, used in multiple EU markets, difficult to replace, or likely to be restricted from 2030.

Step 8: Develop alternative packaging plans

Evaluate reusable, refillable, unpackaged, paper-based, right-sized, or other compliant packaging alternatives.

Step 9: Update supplier and procurement requirements

Communicate future restricted-format rules to suppliers and require compliant alternatives and supporting documentation.

Step 10: Maintain technical documentation

Keep evidence showing packaging classification, exemption basis, replacement plan, supplier declarations, material composition, and conformity assessment.

How ComplyMarket Supports Restricted Packaging Format Compliance

Restricted packaging format compliance under PPWR requires structured packaging data, product mapping, supplier evidence, material classification, use-case assessment, country tracking, technical documentation, and transition planning.

ComplyMarket’s packaging compliance services describe packaging compliance as a market-access topic that may include packaging materials, labelling, recycling, waste management, documentation, registration, reporting, and EPR obligations. ComplyMarket also highlights the value of managing regulations, documentation, supplier compliance, and Digital Product Passport requirements within the ComplyMarket portal.

ComplyMarket can help companies prepare for restricted packaging format requirements by supporting:

• Packaging format inventory management
• Product-to-packaging and market mapping
• Identification of restricted or high-risk packaging formats
• Packaging material and component data management
• Supplier declaration and documentation collection
• Exemption and justification evidence tracking
• Alternative packaging transition records
• Technical documentation and Declaration of Conformity support
• Country-specific packaging requirement monitoring
• EPR and packaging reporting data preparation
• Version control for packaging redesigns and supplier changes
• Audit-ready records for internal and external compliance reviews
• Digital Product Passport and circular economy data readiness

The attached workshop identifies ComplyMarket capabilities across product compliance management software, sustainability reporting software, material compliance software, packaging compliance, Extended Producer Responsibility services, Digital Product Passport, and global market access.

For companies preparing for PPWR packaging restrictions, the challenge is not only knowing which formats are restricted. The real challenge is identifying every affected packaging format across the product portfolio, proving whether exemptions apply, replacing restricted packaging before deadlines, and keeping records updated across suppliers, markets, and business units.

ComplyMarket helps companies move from scattered packaging lists, supplier emails, and manual risk reviews to a structured, traceable, and audit-ready packaging compliance process.