EPR for Food and Beverage: Managing Packaging Compliance in the EU

Food and beverage brands face the most intricate EPR compliance challenge of any product category. A single SKU — say, a 500ml glass juice bottle — might involve primary glass packaging, an aluminium lid, a paper label, a secondary corrugated tray, stretch-wrap film around the tray, and a pallet with stretch wrap at the tertiary level. Every one of those components is a separate line in your packaging declaration, at a different fee rate, in each of the EU countries where that product reaches a consumer.

Get it wrong and you either under-declare (creating a back-liability and enforcement risk) or over-declare (overpaying fees that compound across large volumes). For food and beverage brands shipping tens of thousands of units per month, even a 5% error in declared weight translates into meaningful money.

This guide covers the specific packaging structures, material classifications, and fee considerations that matter most for food and drink brands operating in the EU under the PPWR framework.

Why food and beverage packaging is the hardest to declare

Most e-commerce categories use a fairly standard packaging stack: a product box, a shipping carton, some void fill, and a label. Food and beverage introduces several layers of complexity that other categories simply do not have.

Multiple primary packaging materials on a single product

A glass jar of jam has a glass body, a metal lid, and a paper label. Each material is classified separately for EPR. The glass goes to one material category (and in Spain, to ECOVIDRIO rather than ECOEMBES). The ferrous steel lid goes to metals. The paper label goes to paper/cardboard. Three PRO categories from a single product unit.

Food contact material restrictions

Under the PPWR, packaging that comes into direct contact with food faces additional restrictions on hazardous substances, including a specific ban on per- and polyfluoroalkyl substances (PFAS) that took effect in 2026. Food brands must verify that their primary packaging — particularly flexible plastic films, coatings, and composite laminates — is compliant with both the EPR reporting requirements and the substance restrictions.

Multi-layer flexible films

Snack brands, coffee brands, and ready-meal producers frequently use multi-layer laminates: PET/aluminium/PE, BOPP/PE, metallized BOPP. These composite materials are among the hardest to classify for EPR because different PROs handle them differently. Germany's dual systems typically require you to identify the dominant material by weight. France's CITEO places multi-material composites in a separate category with eco-modulation penalties for low recyclability.

Secondary and tertiary packaging at scale

Food and beverage brands often sell through both D2C e-commerce channels and wholesale/retail channels simultaneously. The packaging levels differ depending on the channel. A case of 24 energy drink cans sold through a B2C website has the cans as primary, the cardboard case as secondary, and the shipping carton as tertiary. The same product sent on a pallet to a retailer adds pallet and stretch wrap at the tertiary level. Your declarations need to reflect the actual channel mix — you cannot use B2B tertiary packaging assumptions for B2C shipments.

Primary packaging: material categories and fee rates

Primary food packaging is where most of the weight and most of the cost concentration sits. The table below shows indicative 2026 fee rates for primary packaging materials across the major EU markets. Rates vary by PRO contract, polymer type, and eco-modulation adjustments.

These rates illustrate why the material classification decision matters so much. A 20g flexible snack pouch made of a BOPP/PE laminate in Germany costs approximately €0.028 per unit in EPR fees. Shift that to a mono-material BOPP structure, and the rate may drop by 10–20% with eco-modulation applied. At 500,000 units per year, that difference is significant.

Secondary packaging for food and beverage

Secondary packaging in food and drink typically falls into one of three structures: corrugated cases, shrink wrap multipacks, or rigid plastic trays with overwrap. Each has different EPR implications.

Corrugated cases and boxes

Corrugated cardboard is the lowest-cost material in EPR terms and also the easiest to classify. A standard corrugated case is paper/cardboard. The fee is low, typically below €0.10/kg in every major EU market. The challenge is weight accuracy: case weights vary by product, and brands often guess rather than measuring. Weigh your actual cases — not the supplier's spec sheet estimate.

Shrink wrap multipacks

The clear or printed polyethylene shrink film holding a 6-pack of water bottles together is secondary packaging. It is plastic, typically LDPE or LLDPE, and it attracts the full plastic fee rate. At 15–20g per multipack, across high volumes, this adds up faster than brands expect.

A common mistake is declaring shrink wrap as transport/tertiary packaging. For B2C channels where the multipack reaches the consumer (e.g., a 6-pack of beer shipped directly to a household), the shrink film is secondary packaging and must be declared at secondary rates.

Beverage carriers and trays

Paperboard beverage carriers (the 4-pack or 6-pack cardboard holder for cans) are secondary packaging made of cardboard. Plastic ring carriers are plastic secondary packaging. Both must be declared. Plastic ring carriers face specific restrictions under the PPWR and several national laws, so verify whether they are still permitted in your target markets.

Tertiary packaging and the B2B versus B2C distinction

Tertiary packaging — pallets, pallet wrap, corner boards — is generally only declared for B2C channels or for direct sales where the packaging reaches the end consumer. For most food brands selling through supermarket chains or wholesale distributors, the retailer takes on the tertiary packaging obligation for their in-store operations.

For D2C food and beverage e-commerce, the line is less clear. If you ship an order to a consumer in a corrugated outer shipper with a cardboard insert and a custom tissue layer, all of that is secondary packaging — none of it is tertiary, because there is no further business entity in the chain before the consumer receives it.

The practical rule: packaging that a consumer will physically handle when opening their delivery is secondary or primary. Only packaging that is removed at a business location before the product reaches a consumer qualifies as tertiary.

Building a food and beverage packaging BOM

A well-constructed packaging Bill of Materials for a food SKU should capture every component at every level. Here is a worked example for a D2C olive oil brand selling 250ml glass bottles.

For each unit sold and shipped D2C, this brand would declare 165g of glass, 6g of aluminium, and 280g of paper/cardboard per order. At 3,000 annual orders to France, that is 495 kg of glass, 18 kg of aluminium, and 840 kg of paper/cardboard declared to CITEO.

The glass obligation, in countries that route it through a glass-specific PRO (Spain's ECOVIDRIO, Italy's CO.RE.VE), requires a separate registration beyond the general household packaging PRO. Factor this into your registration workflow.

EPR fees across multiple EU markets: a practical estimate

Using the olive oil example above (3,000 units shipped to France) and extending to Germany and Spain for 2,000 units each, the annual EPR cost calculation looks like this:

• France (CITEO): (1.485 kg glass × €0.022) + (0.054 kg aluminium × €0.052) + (2.520 kg paper × €0.057) = €0.033 + €0.003 + €0.144 = approximately €0.18 per unit, or €540 for 3,000 units.
• Germany (dual system): (0.165 kg glass × €0.030) + (0.006 kg aluminium × €0.10) + (0.280 kg paper × €0.09) = approximately €0.031 per unit, or €62 for 2,000 units.
• Spain (ECOEMBES + ECOVIDRIO): (0.165 kg glass × €0.034) + (0.006 kg aluminium × €0.095) + (0.280 kg paper × €0.055) = approximately €0.022 per unit, or €44 for 2,000 units.

Total annual EPR cost for this scenario: approximately €646 across three markets, 7,000 units. For a brand shipping 70,000 units per year across the same markets, the cost scales proportionally to roughly €6,460. Manageable — but only if the data is accurate and the registrations are in place.

PFAS and food contact packaging restrictions

Beyond fees, food brands face a specific compliance requirement under the PPWR that other categories do not: the restriction on PFAS in food-contact packaging. PFAS (per- and polyfluoroalkyl substances) have been widely used in grease-resistant paper, microwave popcorn bags, fast-food wrappers, and some flexible food pouches.

From August 2026, food-contact packaging containing PFAS above specified limits is non-compliant with the PPWR. Brands selling food in PFAS-containing packaging face two problems simultaneously: a regulatory violation and a higher eco-modulation penalty at most PROs, since PFAS-contaminated packaging is typically unrecyclable.

If your food products use any coated paper, treated board, or grease-barrier flexible packaging, request PFAS compliance certificates from your packaging suppliers before August 2026.

Practical checklist for food and beverage EPR compliance

• Map every packaging component for each SKU, by material and weight, including all primary sub-components (bottle, lid, label, seal).
• Identify whether any products use glass, triggering a separate glass-PRO registration in Spain (ECOVIDRIO) and Italy (CO.RE.VE).
• Classify multi-layer laminates by dominant material and consult each PRO's composite material taxonomy before filing.
• Obtain PFAS compliance certificates from packaging suppliers for all food-contact materials.
• Separate your sales data by B2C and B2B channels, because packaging level classifications differ between the two.
• Register with the general household packaging PRO and any material-specific PRO (glass, steel) in each target country.
• Use actual weighed component masses, not supplier spec sheet approximations.

For more on the underlying EPR mechanics, see our guide on EPR compliance for e-commerce. For a breakdown of how packaging levels are defined and classified, read packaging levels explained. To understand how eco-modulation can reduce your fees on food packaging, see our eco-modulation optimization guide. For how each material format is scored for recyclability, which drives those eco-modulation adjustments, see recyclability grades under PPWR.

Frequently asked questions

Does primary food contact packaging have a higher EPR fee than secondary packaging?

The fee rate depends on the material, not whether the packaging is primary or secondary. However, food contact packaging often uses materials — PET, HDPE, multi-layer films — that carry higher per-kilogram fee rates than the corrugated cardboard typically used for secondary grouping. In Germany, plastic primary packaging can attract fees of €1.00–1.40 per kg, whereas the cardboard outer case may cost only €0.08–0.10 per kg.

How do I classify a multi-layer food pouch for EPR reporting?

Multi-layer laminates — for example, a PET/aluminium/PE retort pouch — are typically classified under the material with the highest weight fraction, or under a separate "composite" or "other" category depending on the PRO. Germany's dual systems often require you to separate the layers by weight fraction. France's CITEO places composites in a specific category with a higher eco-modulation penalty. Weigh the component and consult the PRO's material taxonomy table before filing.

Are reusable bottles exempt from EPR reporting?

Reusable packaging that is collected back, cleaned, and refilled on a verified closed-loop basis can qualify for a reduced or zero EPR contribution in some EU countries, subject to proof of the return rate. However, simply marketing a bottle as "reusable" does not create an exemption. Most PROs require documented evidence of the actual return and cleaning cycle before granting any credit.

Does the EU plastic packaging tax (Spain's €0.45/kg) apply to food contact plastic?

Spain's Impuesto Especial sobre los Envases de Plástico No Reutilizables applies to non-recycled plastic in packaging, including food contact plastic. There is no blanket exemption for food contact materials. However, the portion of packaging made from certified recycled plastic content is exempt. Brands that can document recycled content through supplier certificates reduce the taxable base accordingly.

My beverage products ship in mixed cases. How do I build the packaging BOM?

Build a BOM per SKU, not per case. Each bottle variant is a separate SKU with its own primary packaging specification. The secondary packaging — the cardboard case or shrink wrap — can be assigned at the case level and then pro-rated across the units inside. If a 12-pack case uses 400g of corrugated board, that is 33g of cardboard per unit. Link both the unit-level primary packaging and the case-level secondary packaging contribution to each SKU in your declaration tool.