Food industry packaging and the PPWR: from the bread crate to hygiene in line with HACCP principles

Key takeaways

• The PPWR (Regulation (EU) 2025/40) applies from 12 August 2026 and replaces the earlier Packaging Directive, 94/62/EC. For food it brings together two fronts: the chemistry of the packaging (PFAS) and its life-cycle (re-use).
• The PFAS restrictions for food-contact packaging apply from 12 August 2026 (Article 5(5)), with thresholds of 25 ppb for a single PFAS, 250 ppb for the sum of PFAS and 50 ppm for PFAS overall, including polymeric forms – with no transitional period for stock produced earlier.
• Re-use targets for transport packaging (Article 29): at least 40% from 2030, and from 2040 an eventual 70%. In controlled loops the bar sits higher: from 2030 the packaging has to be fit for re-use within a re-use system – in circulation inside the company and its group (Article 29(2)) and in supplies to another economic operator in the same Member State (Article 29(3)). That covers the crates in which food travels between plant, warehouse and point of sale.
• Rigid returnable crates in HDPE and PP need no PFAS-type grease-resistant coatings – the material itself provides the barrier. Washed and disinfected on an industrial cycle, they sit within the framework for food-contact materials (1935/2004, 10/2011, GMP 2023/2006) and make it easier to meet hygiene requirements in systems based on HACCP principles.
• In our assessment, the Polish F&B market is a few years behind the DACH markets in rolling out returnable systems in food logistics. The PPWR closes that gap – and the double hit of PFAS plus re-use makes 2026 the year to take the decision, not 2030.

What exactly the PPWR changes for food

The PPWR is a regulation, not a directive – it applies directly, with no national transposition, in identical wording across the whole EU from 12 August 2026. Directive 94/62/EC is repealed on the same day. For a food plant, four layers of new requirements matter most:

• Substances (Article 5). A limit on the PFAS content of all packaging intended to come into contact with food: from 12 August 2026, packaging in which PFAS reach or exceed the limit values may not be placed on the market; below those values it remains permitted (Article 5(5)).
• Re-use (Article 29). Targets for transport packaging (crates, containers, pallets in B2B circulation): at least 40% from 1 January 2030 and an eventual 70% from 1 January 2040; in controlled loops – inside the company and its group (Article 29(2)) and in supplies to another economic operator in the same Member State (Article 29(3)) – full reusability within a re-use system from 2030.
• Design for recycling (Articles 6 and 7). Packaging is to be designed for recycling: recyclability grades from 2030, tightened from 2038 onwards (the Commission criteria are due by 1 January 2028 at the latest). From 2030, plastic packaging must also contain a minimum share of recycled content – with separate thresholds and exemptions for contact-sensitive packaging, food packaging among them. The exemption is not automatic: Article 7(5)(a) lifts the recycled-content requirement from plastic food-contact packaging only where the share of recycled material both poses a risk to human health and renders the packaged product non-compliant with Regulation (EC) No 1935/2004. Both conditions have to be demonstrated in the technical information for the packaging (Article 7(6), Annex VII), so the burden of proof rests with the company.
• Less and lighter (Articles 24 and 43). From 1 January 2030 the empty-space ratio in grouped, transport and e-commerce packaging is capped at a maximum of 50% (Article 24); on top of that, packaging waste per inhabitant is to fall by 5% (2030), 10% (2035) and 15% (2040) compared with 2018 – a target for each Member State (Article 43).

For the food industry, what matters is where the first two layers intersect, and that is the real subject of this article.

The double hit: PFAS and re-use at once

Most Polish material on the PPWR reads the regulation article by article. In the daily practice of a food plant, two of those articles act at the same moment and from two different directions.

The first front – packaging chemistry. PFAS, that is per- and polyfluoroalkyl substances, are sometimes used as a barrier against grease and moisture in single-use paper and board packaging (among them some grease-resistant trays, bags and boxes). The restriction covers all packaging intended to come into contact with food, and PFAS count whatever form they take: as a constituent of the material, as a coating or as an additive. From 12 August 2026, food-contact packaging may not be placed on the market if PFAS reach or exceed the thresholds: 25 ppb for a single PFAS (targeted analysis, polymeric PFAS excluded from quantification), 250 ppb for the sum of PFAS and 50 ppm for PFAS overall, including polymeric forms; where the total fluorine content exceeds 50 mg/kg, the supplier must demonstrate on request what share of that fluorine is attributable to PFAS. Below those thresholds the packaging remains permitted on the market. For planning purposes this has a direct consequence: the regulation provides no transitional period for stock, so packaging produced before August 2026 that exceeds the limits may not reach the market either. The packaging manufacturer must hold technical documentation confirming conformity.

The second front – the packaging life-cycle. In parallel, the PPWR requires the shift from single-use to returnable wherever we are dealing with transport packaging: bread crates, meat containers, dairy crates or the trays in which goods travel from the plant to the retail chain. The targets in Article 29 mean that the returnable model stops being an “eco” choice and becomes part of compliance.

The technical conclusion is straightforward: the two fronts push in the same direction. Single-use materials that have so far coped by means of a chemical barrier are losing that barrier (PFAS), while the single-use model itself is gradually displaced by the re-use targets. A rigid returnable container in HDPE or PP answers both at once: it needs no grease-resistant coating, because the material provides the barrier, and by definition it is reusable packaging.

HACCP and food contact: where the returnable crate meets food safety

For a QA manager the key question is not “returnable or not?” but “returnable and safe?”. Here the PPWR does not operate in a vacuum – it is layered on top of an existing, mature body of food law.

First, the food-contact materials (FCM) framework. Framework Regulation (EC) 1935/2004 requires that a material must not transfer constituents in quantities that could endanger health, and must not change the composition of the food or its organoleptic characteristics in an unacceptable way. Plastics are specified further by Regulation (EU) 10/2011 (the EU list of authorised substances and the migration limits), and the whole must be produced in accordance with good manufacturing practice – Regulation (EC) 2023/2006 (GMP).

Second, hygiene and HACCP. Regulation (EC) 852/2004 obliges food businesses to put in place and maintain procedures based on HACCP principles, together with good hygiene practice. The same regulation, in Annex II, sets one specific condition for reusable packaging: material that is used again must be easy to clean and, where necessary, to disinfect, and must not be a source of contamination.

This is where the advantage of a well-designed returnable crate shows itself: smooth, non-absorbent surfaces with no crevices, washing and disinfection in industrial washers, no PFAS-type coatings or additives. That is how we design our containers for the food industry: we make them from HDPE and PP plastics approved for food contact under the applicable legislation, and their construction – smooth surfaces and the ability to be washed on automatic washing lines – makes it easier to meet hygiene requirements in HACCP systems. Returnable packaging is therefore not an exception within a HACCP system; with the right construction and washing procedure it supports the fulfilment of its hygiene requirements.

By segment: bakery, meat, dairy

The PPWR reads differently depending on what is travelling in the crate. The three most important sub-segments of Polish food processing:

Bakery – bread crates and baker’s boxes

This is the segment in which Poland comes closest to DACH. The returnable baker’s box circulating between bakery and shop has been commonplace here for years, so the logistics model already exists. The PPWR works here to reinforce it: the re-use targets in Article 29 entrench what the market largely does anyway, and the flashpoint lies rather on the single-use side, since grease-resistant bags and liners fall under the PFAS restrictions: below the thresholds they remain permitted, once they reach or exceed them they may not be placed on the market. The direction for the plant is to keep and extend the loop of returnable bread crates (our bakeline series, for instance) and to take stock of single-use contact materials with PFAS in mind.

Meat and poultry – meat containers, meat packaging

The most demanding segment in hygiene terms. What counts here is leak-tightness and liquid drainage, resistance to low temperatures along the cold chain, the absence of crevices that hamper washing, and full compliance with FCM requirements. Returnable EURO-standard meat containers, washed and disinfected between cycles, answer HACCP and the re-use targets at the same time. The PFAS front here concerns mainly single-use trays and absorbent liners, and those are worth taking stock of first.

Dairy and chilled products

Cold-chain logistics and high turnover favour a returnable loop: reusable crates and trays work well in the steady plant–distribution–point of sale cycle. The targets in Article 29, and in controlled loops the full reusability requirement within a re-use system (Article 29(2) and 29(3)), make dairy a natural candidate for early adoption of a returnable system.

Poland and DACH: why we are a few years behind – and why that is good news

This is a thesis we stand by, and it is our assessment of the market rather than a hard statistical fact. In the DACH countries, returnable systems in fresh-food logistics – fruit, vegetables, meat, dairy, bread – have been running in mature, managed pools for decades. The European market for returnable crates (RPCs) itself rests on a proven loop: crates are washed, inspected and returned to the cycle, and the parameters are well documented, with up to 120 re-use cycles over a service life of 7 to 12 years (per Reusable Packaging Europe, factsheet 2022), while environmental analyses put reusable systems in the region of 40–60% lower CO₂ emissions than single-use ones (per Zero Waste Europe, 2020).

Poland has an unusual advantage in this picture: part of the infrastructure and the know-how is already here. bekuplast has been operating since 1985 and is part of an international group headquartered in Ringe, Germany, which grew up in the Mehrweg culture; we also manufacture in Poland, at our plant in Łaziska Górne. That shortens the route: there is no need to invent a system from scratch, because a proven one can be adapted.

Why is being a few years behind good news? Because you can avoid other people’s mistakes and step straight into a mature model instead of working through the whole learning curve. As Henning Wilts of the Wuppertal Institut put it: “we must cut consumption, strengthen re-use systems and, above all, keep more plastics in circulation” (podcast Zukunftswissen.fm, 11 July 2023). The PPWR moves that logic from the level of declaration to the level of obligation, and gives Polish F&B the investment trigger it has so far lacked.

What to do now: a plan for the production director and QA

There is no need to wait for the Polish implementing act, or for 2030. Six steps you can start in 2026:

1. Take stock of your packaging with PFAS in mind. Identify every single-use food-contact material (trays, liners, bags, coatings) and ask your suppliers for documentation of conformity with Article 5.
2. Map the flow: single-use versus returnable. Which routes (plant → warehouse → retail chain) could already run on a returnable loop today?
3. Count your controlled loops. Wherever goods circulate between your own locations, within the group, or to another economic operator in the same Member State, Article 29(2) and 29(3) call for packaging fit for re-use operating within a documented re-use system, and that is the easiest first project.
4. Check whether the returnable packaging supports the hygiene requirements of your HACCP system. The washing and disinfection procedure, FCM declarations of conformity, material parameters.
5. Compare the cost logic, not the “saving from the advert”. Buying your own fleet (CapEx) and the market model of pooling or rental (OpEx) are two different ways of financing the same returnable loop. The result of such a calculation is directional: it shows the break-even point over time (“roughly from which year returnable works out cheaper”), not a payback in months or an ROI in percent. Treat pooling as market context rather than as our offer, since we supply packaging as a manufacturer and do not operate a pool.
6. Cost the full cycle, including fleet replacement. Returnable packaging is not a once-and-for-all purchase; it has a finite service life, so renewing the fleet is a real, recurring cost item alongside washing and reverse logistics. On the single-use side, meanwhile, the product fee under extended producer responsibility (EPR) is going up, and its eventual rates in Poland have not yet been settled, so treat them as an assumption rather than as law in force. Set the horizon at 2030: an earlier start usually means a lower cost of adjustment than putting the decision off.

You will find the full picture of the PPWR requirements in our guide PPWR – what the regulation means for Polish companies, and the mechanics of the re-use targets in the analysis Article 29 – reusable transport packaging. We break the PFAS restrictions themselves down in the article PFAS in food packaging. Our solutions for food plants are gathered on the food processing packaging page, and if you supply retail chains, take a look at the page for retail and FMCG as well. The starting point for the whole campaign, a readiness audit and a directional cost calculator, is in the PPWR Hub.

FAQ

From when do the PFAS restrictions in food packaging apply? From 12 August 2026, under Article 5 of the PPWR (Regulation (EU) 2025/40). The restriction covers packaging intended to come into contact with food, with thresholds of 25 ppb (a single PFAS), 250 ppb (the sum of PFAS) and 50 ppm (PFAS overall, including polymeric forms). No transitional period is provided for stock produced earlier.

Does the PPWR ban plastic food packaging? No. The PPWR does not ban plastics; it requires packaging to be chemically safe (free of PFAS above the thresholds, among other things), recyclable and, increasingly, reusable. Rigid returnable packaging in HDPE and PP fits that direction.

Which returnable packaging is suitable for food contact and for working in a HACCP system? Packaging that meets the requirements for food-contact materials (1935/2004, 10/2011, GMP 2023/2006) and that, under Regulation 852/2004, is easy to clean and to disinfect and is not a source of contamination. In practice: smooth HDPE or PP containers washed on an industrial cycle.

What do the re-use targets cover for food? Article 29 of the PPWR sets targets for transport packaging in B2B circulation: at least 40% from 2030 and an eventual 70% from 2040, and in controlled loops – inside the company and its group (Article 29(2)) and in supplies to another economic operator in the same Member State (Article 29(3)) – full reusability within a re-use system from 2030. It covers, among other things, bread crates, meat containers and dairy crates.

Will bread crates have to be replaced? Not necessarily. Where a returnable loop of baker’s boxes already works, the PPWR tends to entrench it. Attention is needed on the single-use side (liners, grease-resistant bags) in view of the PFAS restrictions, and on the conformity documentation for the packaging already in use.

How does the PPWR differ from EPR? EPR, extended producer responsibility, is a system in which the party placing packaging on the market bears financial, organisational, record-keeping and reporting responsibility for it; the PPWR is a regulation setting design and chemical requirements and re-use targets. They run in parallel rather than as alternatives, and the eventual EPR rates in Poland are still awaiting final legislation.