Regulatory status checked: 10 October 2026.
The EU’s 2026 PPWR guidance gives paper food packaging buyers a clearer classification trigger: composite paper-based packaging containing 5% or more plastic by weight is treated as single-use plastic packaging for the Article 25 restrictions and Annex V prohibitions.
That threshold matters for coated paper cups, food boxes, bowls, plates and portion packs. A product can look and market like paper while its barrier layer changes its regulatory category.
What the 5% threshold means
The European Commission’s official 2026 PPWR guidance explains how composite paper-based packaging should be assessed. When plastic content reaches 5% or more of total packaging weight, the format is considered single-use plastic packaging for the relevant restrictions.
This is a classification rule, not a claim that every format over 5% is automatically banned. Buyers must first identify the product category, use occasion and applicable Annex V entry.
Why foodservice buyers should act now
The PPWR entered application on 12 August 2026, as noted by the European Commission. Procurement files should now contain enough data to calculate the plastic share of each composite SKU.
For a paper cup, record paperboard, inner barrier, outer coating, adhesive, ink and lid separately. For a kraft bowl or takeaway box, include the coating on the base and lid rather than relying on a headline “paper content” claim.
How to calculate plastic percentage
- Weigh the complete packaging unit covered by the assessment.
- Identify every plastic-containing layer and component.
- Add their plastic mass, excluding unrelated secondary packaging.
- Divide plastic mass by total packaging mass and multiply by 100.
- Retain the supplier specification, test method and calculation version.
Run the calculation by SKU and size. A small cup and large cup can use similar coating grammage but have different weight ratios.
Products requiring priority review
- PE- or PLA-lined single-wall paper cups;
- kraft bowls with lids for soup and salad;
- paper to-go boxes with grease barriers;
- coated trays, plates and portion packaging;
- multi-material lids and windows.
Coating names are not enough
PE, PLA and water-based coatings have different structures, but marketing language does not establish the legal percentage. Request dry coating weight, polymer content and finished-unit mass. Our coating comparison guide helps purchasing teams frame the right supplier questions.
A “plastic-free” claim also needs evidence. The calculation should be connected to bill-of-material records and change control, because a barrier reformulation can move a product across the threshold.
Build a PPWR-ready specification
- total finished-unit weight and tolerances;
- paperboard grade and certified source;
- coating chemistry and grams per square metre;
- plastic mass and calculated percentage;
- adhesive, ink, window and lid composition;
- intended food, temperature and holding time;
- food-contact declaration and migration evidence;
- version date and supplier change-notification clause.
Our food-contact safety guide explains why compliance documentation must match the actual intended use.
Do not sacrifice packaging performance
Reducing coating weight can improve a classification result but create leakage, staining or sealing failures. Test hot drinks, soup, oil and delivery time before approving a redesign. See our delivery failure guide and menu-based packaging guide.
Common buyer mistakes
- Using supplier marketing percentages without finished-unit evidence.
- Ignoring adhesive, window or lid plastic.
- Applying one calculation to all sizes.
- Assuming “paper-based” means outside single-use plastic rules.
- Redesigning for a threshold without performance testing.
Frequently asked questions
Is every paper package with 5% plastic banned?
No. The threshold determines classification for the relevant PPWR provisions; the product category and Annex V restriction must still be checked.
Does PLA count as plastic?
Bio-based or compostable marketing does not by itself remove a polymer from the calculation. Obtain legal and technical confirmation for the exact material.
Can buyers use a family average?
SKU-level calculations are safer because size, coating coverage and components change the percentage.
Turn the threshold into a purchasing control
EcoGreenPack supports foodservice brands with coating declarations, unit-weight data, OEM specifications and application testing. Use a documented calculation alongside our supplier audit checklist to build an evidence-led EU paper packaging portfolio.
