Materials · Take-away Packaging (HORECA)

What is take-away packaging and do I need to declare it for EPR?

Your compliance duties for disposable food and beverage containers under the EU PPWR and national laws.

Take-away packaging is service packaging filled at the point of sale with ready-to-eat food or beverages for immediate off-site consumption, and it must be declared for Extended Producer Responsibility (EPR). By 12 February 2027, HORECA operators across the EU must let customers bring their own reusable containers to be filled.

A takeaway cup handed over, for take-away packaging in hospitality and who counts as its producer.

Every paper coffee cup, plastic salad bowl, and cardboard burger box handed to a customer constitutes packaging waste. While traditional retail brands manage their environmental duties through industrial logistics channels, food service operators distribute packaging directly to consumers. This immediate transfer into the residential waste stream places a specific administrative burden on the hospitality sector.

Under modern extended producer responsibility frameworks, you cannot treat disposable food service containers as simple operating supplies. Environmental regulators across Europe are actively shifting the financial and logistical costs of managing hospitality waste directly onto the businesses that fill the packaging. If you operate a restaurant, cafe, bar, or hotel kitchen, you must accurately track your packaging materials to ensure compliance.

What take-away packaging actually means

Under Article 3(1) point 3 of the EU Packaging and Packaging Waste Regulation (PPWR), take-away packaging is formally defined as service packaging filled at attended points of sale with beverages or ready-prepared food that are packaged for transportation and immediate consumption at another location without the need for any further preparation and are typically consumed from the packaging (Packaging and Packaging Waste Regulation (EU) 2025/40). It is a specific subcategory of service packaging designed for the convenience of off-site dining.

The HORECA acronym represents Accommodation and Food Service Activities under the NACE Rev. 2 statistical classification. The legal distinction between take-away and on-site packaging depends heavily on waste management practices.

Take-away packaging represents service packaging filled at the point of sale with ready-to-eat food or beverages designed for immediate off-site consumption.

In France, under Citeo's operational guidelines, the regulatory treatment of food service packaging is split (Mon adhésion - Citeo.com). Packaged meals sold for take-away or home delivery are always subject to household EPR declarations, meaning you must pay fees for every plastic bowl, burger wrap, cup, lid, and carry-out bag. However, for meals consumed on-site, a packaging exemption applies only if the restaurant has implemented a selective waste sorting system - often called the "5 flows" decree - with clearly visible sorting instructions for customers (My membership - Citeo.com). If your restaurant does not operate this sorting system, you must declare and pay household EPR fees on your on-site packaging as well.

Does this apply to me?

Yes, if your hospitality business fills single-use food or beverage containers for customers at the point of sale, takeaway packaging regulations apply to you. Under the PPWR, any economic operator who makes service packaging available for the first time on a Member State's territory must register as a producer (Commission Notice - Guidance document for Regulation (EU) 2025/40 on packaging).

Your exact compliance obligations and thresholds depend on the national territory where you operate:

In Sweden: Under Engångsproduktförordningen (2021:996) §§ 17–22, if you supply drinks in single-use cups or fast food in single-use boxes, you must offer customers the option to have their food or drink served in reusable cups or containers with lids. This reusable packaging must belong to an established rotation system so it can be returned, washed, and reused. This rule applies to any establishment selling more than 75 single-use cups or containers per day. Cups and boxes made entirely of paper or cardboard that are not chemically modified to delay degradation are exempt from this mandate.
In France: You must register with Citeo to declare your packaging volumes and secure a Unique Identifier Number (UIN) from the ecological transition agency, ADEME. Online food delivery platforms are legally required to verify this UIN. If you fail to provide your UIN, the platform must pay the packaging contributions on your behalf and will apply a specific per-order fee to your sales. Faling to register can result in administrative fines of up to €30,000.
In the United Kingdom: Under the packaging EPR (pEPR) regulations, you must collect and report data if your business has an annual turnover of £1 million or more and was responsible for supplying more than 25 tonnes of packaging to the UK market in the previous calendar year. Small producers (supplying 25 to 50 tonnes with a turnover under £2 million) must register and report data annually by 1 April. Large producers must also pay waste disposal fees.

By what dates must HORECA operators meet PPWR's take-away reuse targets?

The implementation of the PPWR introduces strict material bans, consumer choice obligations, and recycling targets for the HORECA sector. Regulators are phasing out several single-use plastic formats in favour of reusable systems.

The table below outlines the critical legal deadlines, material restrictions, and operational targets that apply to take-away and HORECA packaging.

Regulatory Target or Restriction	Requirement
Swedish single-use packaging reduction	Reduce consumption of single-use plastic cups and food containers by 50% compared to 2022
Take-away customer refill obligation	HORECA operators must provide a system for consumers to bring their own containers to be filled
Take-away reusable packaging offer	Final distributors must give consumers the option to obtain takeaway food and drink in reusable packaging
Ban on single-use plastic on-site packaging	Ban on single-use plastic packaging for food and drink consumed within HORECA premises
Ban on single-use plastic HORECA condiments	Ban on single-use plastic condiment packaging, sauces, creamer, and sugar (except for off-site takeaway)
Extruded polystyrene (XPS) format ban	XPS food and beverage containers banned under the amended Single-Use Plastics Directive
Take-away reusable sales target	Final distributors must endeavour to offer 10% of takeaway products in a reusable packaging format

Under Article 33(3) of the PPWR, when you offer takeaway products in reusable packaging, you must do so at no higher cost and under no less favourable conditions than the single-use alternative. Micro-enterprises (employing fewer than 10 people with a turnover under €2 million) are exempt from the 2028 reusable packaging offer and the 2030 10% sales target.

Common misconceptions about take-away packaging

“Take-away packaging is exempt from on-site EPR reporting”

This is incorrect. Under French Citeo rules, if your establishment does not run a verified waste-sorting and selective collection system on the premises, you are legally required to declare and pay household EPR fees on every single-use item consumed on-site.

“Switching to paper cups exempts your business from single-use plastic bans”

This is a common design error. Most paper hot cups and food boxes utilise a thin plastic lining - typically a polyolefin lamination - to prevent liquid leakage. The PPWR defines "composite packaging" by introducing a 5% threshold; any paper-based packaging containing 5% or more plastic by weight is legally treated as single-use plastic packaging and is subject to the 2030 on-site consumption bans.

“Restaurants can charge a premium for serving food in reusable containers”

This is false. The PPWR explicitly states that final distributors must offer products filled in reusable packaging at no higher cost and under no less favourable conditions than those sold in single-use packaging. You cannot use deposits or reuse fees to inflate the base price of the meal.

“Delivery marketplaces are solely responsible for declaring your shipping packaging”

This is a risky assumption. Delivery platforms only declare and pay the packaging contributions for orders placed through their own digital interface, and only if the partner restaurant fails to provide a UIN. For all direct takeaway sales, in-house deliveries, or on-site dining, the restaurant remains the primary producer and must manage its own declarations.

5 examples of take-away packaging

Polyolefin-laminated paper beverage cups

Hot drink cups filled at attended cafe counters. Because they contain a plastic lining, they are treated as composite paperboard packaging under PPWR recyclability classifications.

Uncoated kraft paper burger wraps

Lightweight paper sheets used to wrap sandwiches and burgers. If they do not contain a plastic barrier, they are declared under the standard household paper packaging category.

Semi-rigid aluminium food trays

Metal trays used to package hot meals like lasagna or baked dishes for transport. These are highly recyclable and subject to modulated fee structures based on their material purity.

Expanded polystyrene (EPS) boxes

Rigid foam clamshells historically used for fast food. These are subject to a strict ban under the EU Single-Use Plastics Directive (SUPD), with extruded polystyrene (XPS) formats banned from 1 January 2030.

Kraft paper carry-out bags

Large paper bags with handles used to group and transport multiple food boxes from the restaurant to the customer. These bags are declared under the paper packaging category.

Developing a compliant procurement strategy requires a clear understanding of related packaging definitions.

Term	What it means
Service Packaging	Packaging filled at the point of sale to facilitate the delivery of goods to consumers.
Reusable Packaging	Packaging designed and placed on the market to undergo multiple trips and rotations within a reuse system.
Sales Packaging	Primary packaging designed as a single sales unit for the end user at the point of sale.
Expanded Polystyrene (EPS) Rigid Packaging	Lightweight rigid plastic foam packaging subject to an immediate ban under the EU Single-Use Plastics Directive.
Extruded Polystyrene (XPS) Rigid Packaging	Rigid plastic foam containers commonly used for food service, banned from the EU market starting 1 January 2030.

Frequently asked questions

Am I a micro-enterprise and am I exempt from takeaway reuse rules?

Yes, if your business employs fewer than 10 people and has an annual turnover or balance sheet total under €2 million, you are exempt from the 2028 PPWR takeaway reuse offer obligation. You may also be exempt from the 2030 HORECA on-site single-use plastic ban if you prove that accessing a reuse system is not technically feasible.

Do I have to allow customers to bring their own mugs for coffee?

Yes, under Article 32 of the PPWR, by 12 February 2027, takeaway beverage distributors in the HORECA sector must provide a system for consumers to bring their own containers to be filled. However, you can refuse to fill a container if you consider it unhygienic or unsuitable.

Are paper burger wraps banned under the new EU packaging rules?

No, paper burger wraps are not banned as long as they contain less than 5% plastic by weight. If a paper wrap or box contains 5% or more plastic, it is legally classified as single-use plastic and is banned for on-site consumption starting 1 January 2030.

How do delivery platforms handle my takeaway packaging EPR fees?

Delivery marketplaces are legally required to verify your Unique Identifier Number (UIN) in France. If you do not provide your UIN, the platform must pay your packaging contributions on your behalf and will charge you a specific per-order fee to cover the costs.

What is the daily threshold for reusable containers in Sweden?

If your Swedish food service establishment sells more than 75 single-use cups or food containers per day, you must offer customers the option to have their food or drink served in reusable cups or containers with lids. Establishments selling below this daily volume are exempt from this mandate.

Are condiments in single-use plastic sachets completely banned?

Yes, starting 1 January 2030, single-use plastic packaging for condiments, sauces, coffee creamer, and sugar is banned in the HORECA sector. An exception is made only when these sachets are provided with take-away ready-prepared food intended for immediate off-site consumption.

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Written by Daniel Vaknine, Co-founder – Compliance & Operations · Last reviewed 28 Jul 2026

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