A Cup in Lucerne
The first reaction is almost automatic: this kind of packaging will probably not remain permissible in the EU for much longer.
The EU PPWR
Since 12 August 2026, the Packaging and Packaging Waste Regulation (PPWR – Regulation (EU) 2025/40) has applied directly across the European Union. It replaces national frameworks such as the German Packaging Act (VerpackG) and corresponding rules in other Member States. In Germany, supplementary provisions entered into force through the Packaging Law Implementation Act.
One immediate development was the introduction of EU-wide limit values for PFAS (“forever chemicals”) in food-contact packaging, including disposable cups of the kind many consumers use every day. The regulation also introduced conformity and registration obligations for manufacturers and other economic operators.
Recyclability becomes a legal requirement
What has not yet fully taken effect, however, is the point that stood out most clearly when looking at the cup itself: recyclability.
The PPWR already establishes that all packaging placed on the EU market must be recyclable. The detailed benchmark is still to come. By 1 January 2028, the European Commission is expected to adopt delegated acts setting out design-for-recycling criteria and performance grades from A to C. These requirements become binding from 1 January 2030.
Packaging rated below grade C will be considered technically non-recyclable and may no longer be placed on the market. The practical focus therefore shifts to a central question: can the packaging, taking into account current sorting and recycling technology, be recycled effectively and at scale?
Features such as glued lids, composite materials or paper sleeves may become problematic where they interfere with the required recycling performance.
Four years may appear to leave sufficient time. In practice, it does not. Packaging redesign, supplier qualification, machinery conversion and food-contact approval processes often take several years. Businesses that wait until 2029 to assess compliance risks may find that commercial and technical decisions have already been made for them.
And Switzerland?
On 24 June 2026, the Swiss Federal Council adopted the new Packaging Ordinance (VerpV), which enters into force on 1 January 2027. For the first time, the ordinance covers all categories of packaging. Broader requirements relating to design and recycled content are expected to apply from 2030.
The Swiss framework also promotes recyclability, although it currently does not prescribe detailed recycling-performance criteria comparable to those under the PPWR. For Swiss companies supplying products into the EU, this creates a dual regulatory environment. In practice, compliance is determined not by where the company is established, but by the market in which the packaging is placed.
What matters now
The key issue is not whether a particular cup complies with today’s rules. The more important question is whether it will still comply in 2030 — and who within the organisation is already defining those packaging specifications today.
