EU Packaging Regulations for Horeca Businesses (2026 Guide)

If you operate a café, restaurant, food delivery business or distribute horeca packaging in European markets, 2026 is not a regulatory quiet year. The Green Claims Directive enters implementation. PPWR recyclability requirements continue phasing in. Plastic packaging tax rates are under review in multiple markets. And the tethered lid requirement — already law since July 2024 — continues to create compliance exposure for operations that have not yet addressed it.

This guide is a practical compliance action plan for horeca businesses in 2026. It does not repeat the background of EU packaging regulation (see: EU Plastic Ban Explained for that). It focuses on what you need to have done, verified and documented by the end of 2026 to avoid legal liability, maintain procurement stability and support the sustainability claims you make about your packaging.

The 2026 Compliance Checklist for Horeca Packaging

Work through this checklist by packaging format. Each item is either a current legal requirement, an active financial obligation or a 2026 implementation deadline.

Beverage Cups

• Tethered lid requirement [CURRENT LAW — July 2024]: if you are using separate detachable plastic cup lids, you are currently non-compliant. Action required: switch to tethered plastic lid cup formats, molded fiber lids, or lid-free cups. This is not a future deadline — it is a current obligation.
• Plastic packaging tax [CURRENT — markets: UK, ES, IT, DE, FR, PT]: if you are in these markets and using PE-lined cups and/or plastic lids, you are paying plastic taxes on these items. Action required: verify your actual plastic tax exposure and confirm whether it is being correctly accounted for. If switching to water-based coated cups, confirm water-based coating in writing from your supplier (marketing claims are not documentation).
• PPWR recyclability [PHASING IN 2025–2030]: PE-lined cups that cannot be recycled in standard paper streams face increasing recyclability requirements. Action required: confirm your cup coating specification. If PE-lined, add a transition to water-based coated formats to your procurement roadmap within the next 12 to 18 months.
• PFAS in cup materials [NATIONAL RESTRICTIONS ACTIVE — DE, DK, NL]: if you operate in Germany, Denmark or the Netherlands, PFAS restrictions in food contact materials are already in force. Action required: request PFAS-free third-party laboratory test results for your cup formats covering both paper substrate and coating. See: PFAS-Free Paper Cups Guide.
• Green Claims Directive [IMPLEMENTATION FROM 2026]: any claim about your cups — "eco-friendly cups," "sustainable packaging," "plastic-free" — must be substantiated by verified documentation from January 2026. Action required: build the documentation portfolio now. Specific claims require specific evidence: "plastic-free" requires written confirmation of water-based coating; "PFAS-free" requires laboratory test results; "compostable" requires EN13432 certification. Generic claims without documentation create legal liability.

Food Containers

• EPS containers [BANNED — current]: expanded polystyrene food containers have been banned for EU market supply since July 2021. If any EPS containers remain in your operation, remove them immediately.
• Plastic food containers — EPR obligations [CURRENT]: PP and PET food containers carry EPR contribution obligations in most EU markets. Action required: confirm your EPR registration status and contribution compliance for each market you operate in.
• Bagasse and fiber containers — compostability claims [2026 GREEN CLAIMS]: if you claim your containers are "compostable" in customer communications, you need EN13432 certification from TÜV Austria or DIN CERTCO for the specific container format. Self-declared compostability is not sufficient under the Green Claims Directive.

Lids

• Plastic cup lids — tethered requirement [CURRENT LAW]: see beverage cups section above. This applies to cup lids specifically.
• Molded fiber lids — documentation [2026 GREEN CLAIMS]: if making compostability claims about your lids, EN13432 certification is required. If making PFAS-free claims about barrier-treated fiber lids, laboratory test results are required.

Cutlery

• Plastic cutlery — SUP ban [CURRENT LAW — since July 2021]: plastic cutlery for food service is prohibited. If any conventional plastic cutlery remains in your operation, it must be replaced immediately. Wooden and bamboo FSC-certified alternatives are the standard replacement.
• Wooden cutlery — certification [2026 GREEN CLAIMS]: claims about "sustainable wood" or "FSC-certified cutlery" require FSC certification documentation. Confirm this with your supplier.

Greaseproof Paper

• PFAS in greaseproof paper [NATIONAL RESTRICTIONS ACTIVE — DE, DK, NL; EU-WIDE DIRECTION]: PFAS have been widely used in greaseproof paper for oil resistance. Action required: request PFAS-free laboratory test results from your supplier covering both substrate and any coating. This is the most commonly missing certification in otherwise compliant eco-friendly packaging systems. See: Greaseproof Paper Burger Wrap Guide.

The Green Claims Directive: What Changes in 2026

The EU Green Claims Directive is the single most significant regulatory development for horeca packaging communications in 2026. It requires that specific environmental claims about products and packaging be substantiated by verified evidence meeting defined methodology requirements before those claims are made to customers.

What the Directive Actually Requires

Under the Green Claims Directive, you cannot make a claim about your packaging's environmental characteristics unless:

• The claim is specific — "compostable" rather than "eco-friendly"
• The claim is accurate — the packaging actually meets the specific standard claimed
• The claim is verified — you have third-party documentation confirming it
• The documentation is current — expired certifications do not support active claims

Claims You Cannot Make Without Specific Documentation

Claims You Should Stop Making Without Documentation

The following phrases create Green Claims Directive liability if you cannot substantiate them with specific verified documentation:

• "Eco-friendly packaging" — requires specific substantiated attributes
• "Sustainable cups" — requires specific verified claims
• "Green packaging" — same
• "Environmentally responsible" — not substantiatable as a general claim

The practical guidance: replace general claims with specific ones you can document. "Our cups are water-based coated, PFAS-free and recyclable in standard paper streams" is a defensible set of specific claims if you have the documentation. "Our packaging is eco-friendly" is not.

Plastic Packaging Tax Update: Current Rates and Markets

Plastic packaging taxes are the most direct financial impact of EU packaging regulation on day-to-day procurement costs. Here is the current status by market as of 2026:

For operations in multiple markets, calculate your total annual plastic tax exposure across all markets. For the calculation methodology and per-format cost analysis, see: Sustainable Packaging Cost Analysis.

PPWR 2026 Update: What Recyclability Requirements Apply Now

The EU Packaging and Packaging Waste Regulation (PPWR) adopted in 2024 introduces a phased timeline of recyclability requirements from 2025 to 2030. The 2026 position is:

What Is Currently Required

• Recyclability design requirements under PPWR are in early implementation phase
• Reporting obligations are beginning to apply for larger packaging operators
• The direction of requirements is unambiguous: packaging that cannot be recycled in standard streams faces increasing compliance pressure through to 2030

What Is Coming

• By 2030: mandatory recyclability thresholds will apply across all packaging categories
• PE-lined cups that cannot be recycled in standard paper streams will face direct compliance challenge at that point
• Water-based coated cups are recyclable in standard paper streams — they are forward-compliant for PPWR requirements without any future product change

The Procurement Implication

Operations that have not yet confirmed their cup coating specification should do so now. PE-lined cups purchased today build toward a forced transition in 2028 to 2030. Water-based coated cups purchased today do not require that transition. The procurement decision made in 2026 determines whether you face a planned or reactive compliance change in 2028 to 2030.

2026 Action Plan by Operation Type

Independent Café

Priority actions in order:

1. Confirm tethered lid compliance — if using separate plastic lids, switch to lid-free cups or fiber lids immediately
2. Confirm cup coating specification in writing from your supplier
3. Request PFAS-free test results for your cups if operating in Germany, Denmark or Netherlands
4. Replace any remaining plastic cutlery with FSC-certified wooden alternatives
5. Audit your packaging communications for general sustainability claims you cannot document

Coffee Chain (Multi-Location)

Priority actions in order:

1. Confirm tethered lid compliance across all locations — a single location using separate plastic lids creates network-wide legal exposure
2. Consolidate cup specification to water-based coated formats across the network
3. Build a central documentation portfolio (EN13432, PFAS-free, coating confirmation, EC 1935/2004) that covers all packaging formats used across locations
4. Align marketing and menu communications with Green Claims Directive requirements — remove unsupported general claims, replace with specific documented ones
5. Assess plastic tax exposure across all markets operated and factor into annual procurement cost planning

Food Delivery Operation

Priority actions in order:

1. Confirm tethered lid compliance for beverage packaging
2. Confirm PFAS-free status for greaseproof paper formats — this is the most commonly missing documentation in delivery packaging systems
3. Verify EN13432 certification for any containers claimed to be compostable
4. Confirm plastic cutlery has been fully replaced with SUP-compliant wooden alternatives
5. Build documentation package for your plastic-free delivery packaging claims

Horeca Distributor

Priority actions in order:

1. Audit your product range for compliance documentation gaps — specifically: EN13432 for compostable claims, PFAS-free test results for paper-based formats, coating type confirmation for cups
2. Update supplier contracts to require documentation updates when product formulations change
3. Build per-product customer-facing documentation packages
4. Review your sales communications for Green Claims Directive liability — claims made by distributors about products they sell are subject to the Directive
5. Identify product categories where documentation gaps expose your customers to compliance risk — address these proactively before customer procurement teams do it reactively

Building Your Documentation Portfolio

The practical output of 2026 compliance work is a documentation portfolio: a set of current, verified certificates and test results that cover every packaging format you use and every sustainability claim you make. This portfolio needs to be:

• Product-specific: blanket supplier sustainability declarations are not certification. Each specific product format needs its own documentation.
• Current: EN13432 certifications expire. PFAS-free test results can become outdated if formulations change. Set an annual review calendar for every certification in your portfolio.
• Accessible: documentation needs to be available when customers, procurement teams or regulators request it — not retrievable in three weeks from a supplier.
• Supplier-verified: if a supplier cannot provide the documentation you need, that is a supplier qualification issue, not a documentation management issue. Resolve it at the supplier level.

For the complete supplier qualification framework, see: How to Choose a Food Packaging Supplier for EU Markets. For the horeca procurement framework, see: Horeca Packaging Procurement Guide.