Insight

A cup in Lucerne

Two weeks ago, in Lucerne, a coffee to go. I turned the cup over in my hand, as one does after 25 years in product and waste law: cup and lid, the paper sleeve firmly glued in place. A composite that cannot be assigned to any single-material stream in the sorting facility and can therefore no longer be materially recycled.

Bettina Enderle

Written by Bettina Enderle

Published: August 25, 2026

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.

Trending Articles

What AI Visibility Means for Lawyers


by Josh Rupall and Bryan Driscoll

AI tools increasingly interpret lawyers public information. Clear, consistent and credible sources help ensure they describe legal expertise accurately.

AI dashboard visualizing a lawyer's online profile, reputation, and practice information across mult

Recognizing Legal Leaders: The 2027 Best Lawyers Awards in Australia, Japan and Singapore


by Jamilla Tabbara

Market drivers, diversity trends and the elite practitioners shaping the legal landscape.

Illustrated maps of Australia, Japan and Singapore displayed with their national flags, representing

The Best Lawyers in Canada 2027: Recognizing the Nation's Top Legal Talent


by Jamilla Tabbara

Honoring established leaders and rising practitioners across Canada's legal profession.

3D model of Canada textured with the Canadian flag.

2027 Best Lawyers Awards: Honoring Excellence in the Legal Profession


by Jamilla Tabbara

Recognizing the outstanding attorneys leading top practice areas nationwide.

United States with American flag representing The Best Lawyers in America 2027 awards

Musk v. Altman: The Lawyers Behind the Case


by Jamilla Tabbara

Meet the Trial Lawyers Shaping One of AI's Biggest Legal Disputes.

Portrait photos of Elon Musk and Sam Altman positioned in front of the OpenAI logo.

Announcing the 2027 Best Lawyers Awards: Austria, Germany and Switzerland


by Jamilla Tabbara

Celebrating the legal professionals throughout Central Europe.

Graphic displaying three-dimensional map cutouts of Austria, Germany and Switzerland.

The Legal Teams Behind the Blake Lively–Justin Baldoni Settlement


by Grace Greer

A closer look at the legal teams and attorneys involved in the Blake Lively–Justin Baldoni litigation and its resolution.

Split-screen image of Blake Lively and Justin Baldoni

The Best Lawyers in France 2027: Peer-Reviewed Excellence


by Jamilla Tabbara

Seventeen editions of peer trust, a growing profession and a dynamic legal market.

3D Map of France with National Flag Graphic

New England's Climate Litigation Surge


by Bryan Driscoll

What law firms need to know

New England's Climate Litigation Surge: What Firms Must Know headline

What Is a Quitclaim Deed? Uses, Risks and When to Get Help


by Bryan Driscoll

A quitclaim deed can be one of the fastest ways to transfer property but knowing when it's the right tool and when it isn't, can save you from serious legal and financial headaches down the road.

One hand holding a wooden house model and another holding house keys.

Rules on Gifting Money to Family: What to Know


by Bryan Driscoll

Generosity often runs ahead of paperwork. Here's how to give to loved ones without surprising the IRS, your estate plan or your relationships.

An open gift box filled with US $100 bills next to a lid tied with a red bow.

An Employee's Guide to Non-Disclosure Agreements (NDA)


by Bryan Driscoll

Before you sign anything, here's what you need to know about non-disclosure agreements.

Figure stands before an open giant book, holding a large key, facing a keyhole on the inner page.

How to Optimize Your Best Lawyers Profile for AI Search


by Everett Sizemore

Learn how a complete, well-structured Best Lawyers profile can strengthen your visibility and accuracy across AI search platforms.

A laptop screen displaying the Best Lawyers profile dashboard showing customizable sections.

Who Can Override a Power of Attorney?


by Bryan Driscoll

A power of attorney carries real legal authority, but it isn't absolute. Here's who can step in to revoke, restrict or set it aside.

Close-up of a power of attorney document, symbolizing legal authority, revocation rights, guardiansh

Best Lawyers Launches ChatGPT App


by Jennifer Verta

Expanding Trusted Legal Guidance Into AI-Driven Search

A glowing digital network overlay on a person typing on a laptop, representing AI in legal search.

Turn Client Questions Into Content That AI Search Can Find


by Bryan Driscoll and Manny Candal

Client questions are becoming search inputs. Your firm’s content should answer them clearly.

Pile of question marks with a single bright yellow question mark in the center, representing search.
Smithy AI Tap to expand

Welcome to Smithy AI the Best Lawyers Assistant

I can help you find attorneys, compare firms, explore practice areas, and surface rankings curated from the Best Lawyers methodology.

Not legal advice This assistant provides general information only. For guidance on your specific situation, please consult a licensed attorney.
Learn about Best Lawyers Research Process
Suggested prompts
Chat limit reached
You've reached the message limit for this chat. To keep exploring, browse Best Lawyers directly or come back later to start a fresh conversation.
Browse Best Lawyers