From 1 January 2030, Article 25 of the EU Packaging and Packaging Waste Regulation (PPWR) prohibits placing on the market packaging in the six formats and uses listed in Annex V. These include certain retail multipacks, fresh-produce packs, food-service packaging, individual portion packs, accommodation toiletries packaging and very lightweight plastic carrier bags. The deciding details are the packaging’s material, contents and intended use.

The PPWR generally began applying on 12 August 2026; the Annex V restrictions have their own 2030 start date. The rules cover packaging placed on the EU market regardless of origin, including packaging sourced from China. The starting point for assessing a format is Regulation (EU) 2025/40, read alongside the relevant Commission guidance and destination-country provisions.

The six restricted formats at a glance

Retail multipacks: what the wrapping is for matters

Grouped packaging brings several sales units together and can be removed without affecting the products’ characteristics. Its legal definition includes consumer multipacks, shelf-restocking arrangements and stock-keeping or distribution units. Annex V point 1 targets a narrower use: single-use plastic convenience packaging at the point of sale that enables or encourages multiple purchases. The explicit exclusion for packaging necessary to facilitate handling therefore matters.

A film wrap joining two individually saleable sunscreen bottles as a promotional pair is a format to reassess. It creates a consumer bundle. Wrap securing shipping cartons on a pallet serves a transport function and is not caught by point 1 simply because it is plastic and used once. Transport packaging has separate PPWR requirements. Equally, a gift set is not automatically restricted merely because it contains several products: the material and use conditions still determine the outcome.

For a promotional pair, a paperboard sleeve or carrier may preserve the offer and keep the products together. At CMIC, we can develop the structure around the actual bottles, checking how it grips them, carries their weight and responds to retail handling. A physical sample makes those choices tangible before the artwork is finalized. Any plastic film or laminate in the proposed construction also needs attention; a paper-based appearance alone does not establish its material classification.

Hotel toiletries: changing the material does not remove the restriction

Annex V point 5 is material-neutral. It covers single-use packaging for cosmetics, hygiene and toiletry products in the accommodation sector when intended for an individual booking only and for disposal before the next guest arrives. The examples include shampoo bottles, hand and body lotion bottles, and sachets around bar soap. This entry has neither a plastic-only qualifier nor a volume threshold for miniature bottles.

For a toiletries brand, the same small shampoo bottle can require different assessments in different channels. Supplied for one hotel booking, with its packaging intended to be discarded before the next guest, it matches the described use. Sold as a travel product through ordinary retail, it falls outside this accommodation-specific entry. Replacing a hotel soap’s plastic wrapper with a disposable paper sachet leaves the booking and disposal conditions unchanged.

A dispensing or refill arrangement designed to work across bookings changes the service pattern more substantially. The dispenser, refill container and supporting packaging each need their own assessment. We can develop protective cartons and branded paper components around that arrangement, coordinating their dimensions and presentation with the product system the brand chooses.

Providing an in-scope miniature only on request does not create an exemption. The Commission’s updated FAQs also identify no automatic exemption merely because the miniature is purchased at the hotel. Its intended use for a booking and intended disposal remain decisive.

Fresh produce: below 1.5 kg, with specific national exemptions

Annex V point 2 concerns single-use plastic packaging for less than 1.5 kg of pre-packed, unprocessed fresh fruit and vegetables. A 500 g plastic pack of unprocessed fresh tomatoes meets the category and weight conditions, subject to any applicable exemption. A pack containing exactly 1.5 kg is outside this particular weight condition. The entry does not establish a general ban on all fresh-food packaging.

Member States may establish exemptions where a need is demonstrated to avoid water loss, loss of firmness or turgidity, microbiological hazards, physical shocks or oxidation. A further ground concerns preventing organic produce from mixing with non-organic produce to meet EU organic certification or labeling requirements, where no other way of achieving this avoids disproportionate economic and administrative costs.

These are grounds for a Member State exemption, rather than an exemption a supplier can declare for itself. A brand seeking to retain a protective plastic pack needs to connect its product’s needs to the provisions in the destination country. For a paper-based replacement, ventilation, moisture exposure and bruising remain practical design questions: removing plastic still has to leave a pack that protects the produce through its intended journey.

Food service: on-site packaging and portion packs have different tests

Point 3 covers food and beverages filled and consumed on the premises in the hospitality, restaurant and catering sector, commonly called HORECA. Premises include indoor and outdoor eating areas, standing areas and shared spaces such as food courts. Moving service from a dining room to its terrace does not change that condition. Establishments without access to drinking water are expressly exempt.

The Commission’s FAQs include hotel room service and explain that sporting venues, entertainment venues and festivals can fall within HORECA when they offer meals or beverages ready for immediate consumption. Food delivered outside a hotel’s premises falls outside point 3, although separate takeaway requirements may apply.

Article 25(4) also allows Member States to permit a microenterprise exemption for point 3 where avoiding the packaging, or obtaining access to the infrastructure necessary for a reuse system, is demonstrably not technically feasible. This depends on national permission and the specified conditions; small-business status alone does not establish an exemption.

Point 4 concerns individual portions or servings of condiments, preserves, sauces, coffee creamer, sugar and seasoning in single-use plastic packaging in HORECA. It does not repeat point 3’s requirement that the packaging be filled and consumed on the premises. Instead, it provides two specific exceptions:

• Takeaway food: the portion pack is provided together with ready-prepared takeaway food intended for immediate consumption without further preparation.
• Medical care: the packaging is required for safety and hygiene in an establishment where there is a medical requirement for individualized care, such as a hospital, clinic or nursing home.

A sauce sachet accompanying a ready-to-eat takeaway sandwich can meet the first exception; the same sachet provided with a sit-down meal cannot rely on it. Likewise, a general preference for individually wrapped portions does not establish the medical exception. The packaging must serve the specified safety and hygiene need associated with medically required individualized care.

Very lightweight carrier bags: below 15 microns

Point 6 uses a precise thickness category: plastic carrier bags with a wall thickness below 15 microns. Carrier bags may have handles or no handles and are supplied to consumers at the point of sale. The restriction retains exceptions for bags required for hygiene reasons or provided as sales packaging for loose food when this helps prevent food waste.

A 12-micron bag does not escape the restriction because it is compostable or biodegradable: the Commission’s FAQs expressly include those versions. It still needs to meet an applicable exception. A bag at 15 microns or above falls outside point 6’s thickness definition, but national carrier-bag measures under Article 34 may still affect it. Even bags qualifying for the EU-level hygiene or food-waste exception can be subject to proportionate, non-discriminatory national restrictions.

How paper and mixed materials change the answer

Material substitution has different consequences across the list. Points 1–4 specify single-use plastic packaging, so a suitable paper-only alternative can change whether those restrictions apply. Point 5 covers accommodation toiletries packaging in any material. Point 6 specifically concerns plastic carrier bags. The format’s purpose must therefore be settled alongside the material choice.

Paper-based packaging can contain plastic barriers or laminates. Sections 16–17 of the Commission guidance published in June 2026 treat relevant composites containing more than 5% plastic as covered by points 1–4 when their format and use also match. Packaging below 5% plastic is described as outside those particular bans. This is Commission interpretation; the guidance does not amend the regulation.

The published wording conflicts at exactly 5%. It describes packaging containing 5% or more plastic as covered, while also describing packaging containing not more than 5% as excluded. A design specified at exactly that boundary therefore needs clarification before the percentage is used to justify its classification. The separate Single-Use Plastics Directive can also apply to packaging partly made from plastic outside these Annex V restrictions, so a lower plastic share is not a general exemption from EU plastics rules.

For development, the useful information is the complete construction and material breakdown of the relevant packaging unit. An uncoated board sleeve and a paper sachet with a plastic barrier may both look paper-based while performing very different jobs. We can bring material information and structural samples together so the brand can compare protection, handling and appearance with the proposed packaging route.

Format eligibility and material performance are separate checks. A recyclable film can still be a single-use plastic convenience wrap within point 1. Adding recycled content does not remove the restricted use. Equally, a pack outside Annex V still needs to meet the other PPWR requirements applicable to it.

National rules and the guidance still to come

Under Article 25(2), Member States may retain restrictions adopted before 1 January 2025 on Annex V formats and uses made from materials not listed in the relevant entry. An existing national restriction can therefore reach a paper alternative that falls outside an EU plastic-specific restriction. Separately, Article 70(4) allows national restrictions concerning points 2 and 3—fresh produce and on-premises food-service packaging—to continue until 1 January 2030.

These provisions, together with national produce exemptions, the possible point 3 microenterprise exemption and carrier-bag measures, make the destination country relevant to the assessment. Permission or an exemption in one Member State should not be treated as an EU-wide result.

The six Annex V categories are already adopted requirements. Article 25(6) requires more detailed Commission guidelines by 12 February 2027, including examples, exemptions and a non-exhaustive list of fruit and vegetables excluded from point 2. The Commission’s August 2026 FAQs described that work as underway. Those guidelines should help clarify boundary cases; the 1 January 2030 restriction date is already set.

The practical distinction is visible in two familiar projects: a retail promotion may keep its purpose while moving from film to a suitable paperboard structure; a hotel amenity may need a different way of providing the product across bookings. Recognizing which change matters gives sampling and material selection a clear purpose.

If you are reassessing a retail bundle or the paper packaging around a refill offer, our EU packaging solutions can help develop the relevant structures, materials and samples. For the broader planning route across your product range, see our guide to what product brands need to redesign before 2030.