Who is a final distributor in the HORECA sector under PPWR?

A final distributor in the HORECA sector is any hotel, restaurant, or catering business that delivers packaged products or refillable food and beverages directly to the end user. From 12 February 2028 they must offer takeaway drinks and ready-prepared food in reusable packaging at no extra cost. (47 words)

The Packaging and Packaging Waste Regulation introduces profound operational changes for the hospitality and food service industry. Historically, cafes, fast-food outlets, and hotels have relied heavily on single-use packaging for convenience, speed, and hygiene. Millions of tonnes of plastic and paper waste are generated every year across the European Union from disposable coffee cups, takeaway boxes, and single-serving condiment sachets. To curb this trend, European authorities have placed specific legal responsibilities on the last link in the supply chain: the business that physically hands the food or drink to the consumer.

By clearly defining the final distributor, the law ensures that restaurants, pubs, and caterers take an active role in the transition to a circular economy. Instead of merely purchasing disposable packaging from a supplier and handing it out, a final distributor must now adapt its entire operational model to accommodate reusable containers, consumer-owned cups, and new take-back systems. The rules force a deliberate shift away from a throwaway culture, making reuse and refill the standard options for European consumers whether they are dining in or taking food away.

What being a final distributor in HORECA actually means

The legal definition of this role hinges entirely on the act of supplying the final consumer. It does not matter whether the business manufactures the food itself in a kitchen or simply resells pre-packaged goods from a display fridge.

"final distributor means the natural or legal person in the supply chain that delivers packaged products, including through re-use, or products that can be purchased through refill to the end user" (Packaging and Packaging Waste Regulation (EU) 2025/40).

In the context of the regulation, the HORECA sector specifically refers to Accommodation and Food Service Activities. This encompasses everything from large multinational hotel chains to independent corner cafes and street food vendors. If your business operates in this space, you are the final distributor for the packaging that leaves your counter. This role carries mandatory obligations to change how takeaway and dine-in services are packaged and presented to the public.

By 12 February 2027, you must allow consumers to bring their own containers for hot or cold beverages and ready-prepared takeaway food. A year later, by 12 February 2028, you must actively offer these takeaway products in reusable packaging within a functioning re-use system. The regulation mandates that choosing the sustainable option cannot penalise the consumer financially. The reusable packaging option must be offered at no higher cost, and under no less favourable conditions, than the equivalent single-use packaging. You are also legally required to inform customers of these options at the point of sale via clear signage.

Does this apply to me?

Yes, if you operate a business in the hotel, restaurant, or catering sector within the European Union and supply food or drinks in packaging directly to consumers. This includes bakeries selling takeaway sandwiches, pubs offering coffee to go, hotel breakfast buffets providing single-serving jams, and fast-food chains serving meals on their premises.

However, the regulation includes safeguards to protect very small businesses from disproportionate financial and administrative burdens. If your business qualifies as a micro-enterprise under Recommendation 2003/361/EC (typically meaning you have fewer than 10 employees and an annual turnover or balance sheet total that does not exceed EUR 2 million), you are completely exempt from the specific obligation to offer takeaway products in reusable packaging.

Furthermore, exemptions apply based on the physical footprint of your premises. For instance, the mandatory 2030 re-use targets for beverages do not apply in a given calendar year if your sales area is not more than 100 square metres. There are also exemptions for final distributors located on islands with fewer than 2,000 inhabitants, or in sparsely populated municipalities, provided the population centre itself does not exceed 5,000 inhabitants.

When do PPWR reuse and refill obligations start for HORECA final distributors?

Common misconceptions about HORECA packaging rules

"I must accept any container a customer brings in for refill."

While you must provide a system for consumers to bring their own containers by 2027, you are never forced to accept dirty or unhygienic items. The regulation explicitly allows economic operators to refuse a consumer's container if it does not comply with your communicated refill rules, particularly if you consider the container to be unhygienic or unsuitable for the safe sale of food and drink. Furthermore, you bear no legal liability for hygiene or food safety issues arising from the use of a consumer-provided container.

"I can charge a premium for serving food in reusable packaging."

The law strictly prohibits this pricing strategy. When you offer products in reusable packaging, you must offer them at no higher cost and under no less favourable conditions than the same product sold in single-use packaging. You can, however, take a fully refundable deposit to ensure the physical container is returned to your business.

"All single-use condiment sachets are completely banned."

The ban on single-use plastic packaging for individual portions of condiments, sauces, coffee creamer, and sugar applies to the HORECA sector, but there is a very specific exception. These individual plastic portions are still permitted if they are provided together with takeaway ready-prepared food intended for immediate consumption. The restriction primarily targets dine-in scenarios where bulk dispensers or ramekins can be used instead.

"I only have to offer reusable packaging if the customer specifically asks for it."

You must be proactive in your communication. By 12 February 2028, you must inform consumers at the point of sale, through clearly visible and legible information boards or signs, about the possibility of obtaining their products in reusable packaging. You cannot hide the option or wait for the consumer to initiate the request.

5 examples of final distributor obligations in practice

• Refusing a dirty coffee cup: A customer brings a visibly soiled, unwashed travel mug to a cafe for a morning refill. The barista refuses to fill it, citing the cafe's hygiene policy. This is legally permitted under the regulation, which protects the distributor from having to handle unsanitary items.
• Banning plastic plates for dine-in: A fast-food restaurant currently serves burgers and fries on single-use plastic trays and plates to customers sitting in its dining area. By 1 January 2030, it must replace these with washable, reusable tableware, as single-use plastic for dine-in consumption is prohibited.
• Exempting a tiny kiosk: A small takeaway coffee kiosk operates in a train station with a total sales area of just 45 square metres. Because its sales area is well under the 100-square-metre threshold, it is fully exempt from the 2030 target requiring 10% of beverages to be sold in reusable packaging.
• Swapping hotel toiletries: A boutique hotel currently provides 30ml single-use plastic bottles of shampoo and body wash in its bathrooms for individual guest bookings. By 1 January 2030, this packaging format is banned, prompting the hotel management to install large, refillable pump dispensers mounted on the shower walls.
• Handling takeaway condiments: A pub serves a dine-in customer fish and chips and provides ketchup from a large communal glass pump bottle, avoiding single-use plastic sachets. However, for a delivery order of the exact same meal, the pub includes single-use plastic ketchup sachets in the bag, which remains legally permitted for takeaway food.

Terms related to final distributor

Frequently asked questions

Do I have to accept customers' own takeaway containers?

Yes. By 12 February 2027, final distributors in the HORECA sector must provide a system allowing consumers to bring their own containers for hot or cold beverages and ready-prepared takeaway food. However, you can set strict hygiene rules for these containers and refuse them if they are unsuitable. Importantly, you are not liable for any food safety issues caused by the customer's own container.

Can I still use single-use paper cups for dine-in customers?

The 1 January 2030 restriction specifically bans single-use plastic packaging for foods and beverages filled and consumed within HORECA premises. Therefore, paper or cardboard packaging that does not contain plastic polymers may still be permitted for dine-in, provided it meets all other recyclability, safety, and design requirements dictated by the regulation.

How do I prove that I am a micro-enterprise to get an exemption?

To qualify for the micro-enterprise exemption from the 2028 re-use offer obligation, you must meet the criteria set out in Commission Recommendation 2003/361/EC. In practical terms, this generally requires demonstrating that your enterprise employs fewer than 10 persons and has an annual turnover or annual balance sheet total that does not exceed EUR 2 million.

If I sell beverages in reusable packaging, who takes it back?

As a final distributor, you are required to take back, free of charge, all reusable packaging of the same type, form, and size that you make available on the market within that specific re-use system. End users must be able to return the packaging at your point of sale or in close proximity to it, and you must fully redeem any associated deposits to the consumer.

Are highly perishable drinks like milk subject to re-use targets?

No. The mandatory 2030 re-use targets for beverages do not apply to highly perishable beverages, which explicitly includes milk and milk products. They are exempt because these sensitive liquids are prone to rapid microbiological spoilage caused by bacteria or yeasts, and require specific aseptic technology to maintain a safe shelf life that is difficult to guarantee in standard re-use systems (Packaging and Packaging Waste Regulation (EU) 2025/40 (PDF)).

Sources:

• Packaging and Packaging Waste Regulation (EU) 2025/40