What is service packaging and do I need to declare it for EPR?

Yes, you must declare service packaging for Extended Producer Responsibility (EPR), but under the EU PPWR and most national schemes, the compliance obligation is shifted to the manufacturer or importer who first supplies the empty packaging. In France, suppliers of empty service packaging who fail to register can face fines of up to €30,000.

Point-of-sale packaging is a staple of the retail, food service, and hospitality industries. When a bakery wraps a loaf of fresh bread, a boutique drops clothing into a branded carrier bag, or a fast-food outlet serves a hot meal in a cardboard box, these businesses are utilising service packaging to facilitate the immediate delivery of goods (Multi-Material Stewardship Manitoba steward guidebook). Because these materials are intended for immediate, one-way use by the final consumer, they inevitably enter the residential waste stream shortly after purchase (FOR STEWARDS GUIDEBOOK - Multi-Material Stewardship Manitoba).

To prevent municipal waste systems from being overwhelmed by the costs of sorting and recycling these short-lived items, Extended Producer Responsibility (EPR) regulations treat service packaging with extreme scrutiny. However, managing data declarations for every individual bakery, coffee shop, and dry cleaner would create an impossible administrative bottleneck. Consequently, environmental laws contain specific transfer mechanisms that protect small, front-line businesses while ensuring that the environmental footprint of these checkout-counter materials is fully accounted for and funded (Everything you need to know about the PPWR - Verpact).

What service packaging actually means

Under Article 3(1) point 1(d) of the EU Packaging and Packaging Waste Regulation (PPWR), service packaging is defined as an item that is designed and intended to be filled at the point of sale in order to dispense the product. This legal definition is complemented by point 1(e), which covers disposable items that are sold and filled, or designed and intended to be filled, at the point of sale, performing a packaging function. The unifying legal characteristic of service packaging is that it is supplied empty to the retailer or food service provider and is filled only at the physical or digital checkout to facilitate the delivery of goods.

This classification depends entirely on the point at which the container is filled with a product, rather than the physical structure of the material itself. Regulators draw a strict distinction between items sold empty as consumer products and those used as service packaging. For example, if a paper cup is sold empty in a sleeve on a retail shelf for home use, it is treated as a product and is exempt from packaging EPR. However, if that same paper cup is filled with coffee at an attended cafe counter or a supermarket drink station, it is legally classified as service packaging and is subject to full EPR obligations.

Service packaging includes any packaging item filled at the point of sale by a retail, food service, or other service provider to protect or facilitate the delivery of goods to the consumer.

In North American schemes, such as the Canadian stewardship programmes managed by Multi-Material Stewardship Manitoba (MMSM), service packaging is defined similarly. The regulations identify these materials as non-branded or branded bags, boxes, wraps, and hangers supplied at the point of sale to facilitate the consumer's transport of purchased items.

Does this apply to me?

If your business manufactures, imports, or distributes empty service packaging, the answer is yes, as you are classified as the producer under most environmental frameworks. To minimise the administrative burden on small businesses that fill service packaging at the point of sale, modern regulations shift the legal and financial responsibility upstream. This means that the local bakery or boutique filling the bag is legally relieved of the duty to register and pay weight-based fees; instead, the company that sold them the empty boxes or bags must carry out the declarations.

The specific compliance mechanics vary depending on the national jurisdiction in which the empty packaging is sold:

• In Sweden: Under Swedish Ordinance 2022:1274, companies that manufacture or import empty service packaging into Sweden are defined as the obligated packaging producers. To prevent thousands of small kiosks, growers, and cafes from having to register individually, the Swedish Environmental Protection Agency (Naturvårdsverket) requires the upstream supplier of the empty bags, egg trays, and boxes to register and pay the weight-based fees. Furthermore, under Swedish Ordinance 2021:996 on single-use products, establishments selling more than 75 single-use plastic cups or food containers per day must offer customers the option to have their food or drink served in reusable cups or containers with lids.
• In France: Under Article L541-10 of the French Environmental Code, packaging suppliers placing empty service packaging on the French market must register with an approved eco-organisation like Citeo. These suppliers must secure a Unique Identifier Number (UIN) from the French agency for ecological transition, ADEME, to prove their compliance to their customers. Fines for placing non-compliant packaging on the French market can reach up to €30,000.
• In the Netherlands: Verpact applies the same principle, obligating the producer or importer of empty point-of-sale packaging. If a Dutch company imports unbranded carrier bags from outside the EU and sells them to local shops, that importer is the obligated producer and must declare the packaging weight.
• In the United Kingdom: The UK packaging EPR (pEPR) regulations apply to businesses with an annual turnover of £1 million or more that supply more than 25 tonnes of packaging. Under these rules, small producers must collect packaging data and report it annually by 1 April, while large producers must report twice a year and pay waste disposal fees. If a retailer is below these thresholds, the upstream supplier of the empty packaging must report the data instead.

What fee thresholds and deadlines must service packaging suppliers track?

EPR systems use quantitative thresholds, deadlines, and financial metrics to manage service packaging. If you are an upstream supplier of empty point-of-sale materials, you must monitor these figures to maintain market access.

The table below outlines the critical regulatory thresholds, fee rates, and system targets that apply to service packaging across different jurisdictions.

Under the Verpact system in the Netherlands, highly recyclable rigid service packaging formats can qualify for fee discounts of up to €0.60 per kilogram under the Fee Modulation plastic system. Conversely, hard-to-recycle flexible plastics face higher starting fees to encourage eco-design. Under the PPWR, all service packaging must achieve a recyclability performance grade of A, B, or C by 2030, meaning any format with less than 70% recyclability will be classified as technically non-recyclable and banned from the market.

Common misconceptions about service packaging

• Retailers who fill bags at checkout are always the obligated producers. This is a widespread misconception that causes unnecessary administrative panic among small businesses. Under the PPWR and Swedish national laws, the packaging manufacturer or importer who supplies the empty service packaging to the shop is the legally obligated producer. The shopkeeper only becomes the producer if they import the empty packaging themselves or brand the packaging with their own registered name or trademark.
• Service packaging sold empty to consumers carries no EPR obligations. This is incorrect. If a manufacturer sells empty paper cups or disposable plates in bulk packs to consumers for private home use, they are treated as retail products and are not classified as packaging under EPR schemes. However, if those same items are sold to a business to be filled at the point of sale, they are service packaging, and the upstream manufacturer must declare them.
• Paper bags are exempt from EPR declarations because they are not plastic. While paper and cardboard are highly recyclable and subject to lower eco-modulated fees, they are not exempt from extended producer responsibility. Every paper checkout bag, bakery wrap, and cardboard box must be weighed, recorded, and declared. Suppliers must pay the corresponding paper and cardboard fees, which fund the collection and treatment of paper waste.
• The component threshold rule allows you to ignore labels and caps under 5% of the weight. Under Canadian stewardship rules like MMSM, if an integrated component like an adhesive label weighs less than 5% of the overall packaging weight, its weight is not ignored. Instead, it is reported under the material category of the main container (e.g., reporting a paper label under the plastic category of a water bottle). It must still be declared.

5 examples of service packaging

• Paper checkout bags. Kraft paper carrier bags provided by grocery stores at the cash register to help customers transport their purchases. These must be reported by the packaging manufacturer under the paper category.
• Disposable hot beverage cups. Non-foam paper cups filled at attended coffee shop counters to serve takeaway hot drinks. The plastic lid and any cardboard sleeve are also declared as part of the overall service packaging unit.
• Cardboard pizza boxes. Fluted corrugated boxes filled with hot pizzas at takeaway outlets. These are declared by weight under the corrugated cardboard category by the manufacturer of the empty box.
• Plastic bulk produce bags. Thin polyethylene rolls placed in supermarket aisles for consumers to bag loose fruits and vegetables. These must be tracked and reported under the plastic film category.
• Plastic hangers provided with clothing. Rigid plastic hangers supplied to consumers alongside a purchased item of clothing to facilitate its transport. These are classified as service packaging and must be reported under the rigid plastic packaging category by the clothing retailer or importer.

Terms related to service packaging

To successfully navigate packaging compliance, you must understand how point-of-sale materials relate to neighboring legal definitions.

Frequently asked questions

Am I an obligated producer if I only fill paper bags at my retail store?

No, under the PPWR and Swedish regulations, if you only purchase empty bags and fill them at your shop's checkout, you are not the obligated producer. The manufacturer or importer who sold you the empty bags is responsible for registering and paying the weight-based EPR fees.

Are plastic clothes hangers classified as service packaging?

Yes, if a plastic hanger is provided to a consumer alongside a purchased item of clothing to facilitate its transport, it is legally classified as service packaging. It must be reported under the rigid plastic packaging category by the clothing retailer or importer.

Do paper bags containing plastic linings count as mono-materials?

Under the PPWR, any packaging that contains less than 5% plastic by weight is legally classified as a mono-material paper packaging item. If the plastic lining represents 5% or more of the packaging's total weight, the item is classified as composite multi-material packaging.

What is the penalty for selling empty service packaging in France without registration?

If you manufacture or import empty service packaging for the French market and fail to secure a Unique Identifier Number (UIN) from ADEME, you can face administrative fines of up to €30,000 per company. You are also subject to weight-based penalties for undeclared packaging.

Do I need to declare the cardboard tray used for takeaway coffee?

Yes, molded pulp coffee trays used to carry takeaway beverage cups are classified as service packaging. The manufacturer or importer who supplies these trays empty to coffee shops is responsible for declaring their weight.

How is service packaging data tracked in the Netherlands?

Under Verpact guidelines, suppliers must record the total weight of empty service packaging in kilograms, categorised by material type. For companies placing under 10,000 kg of packaging on the Dutch market annually, a simplified declaration is available.

Sources:

• Cradle to Cradle Certified® Product Standard Version 4.0
• Everything you need to know about the PPWR - Verpact
• Multi-Material Stewardship Manitoba steward guidebook
• FOR STEWARDS GUIDEBOOK - Multi-Material Stewardship Manitoba
• Commission Notice - Guidance document for Regulation (EU) 2025/40 on packaging
• Packaging and Packaging Waste Regulation (EU) 2025/40