PPWR Banned Packaging Formats: Article 25 & Annex V Guide
PPWR Banned Packaging Formats: The Article 25 & Annex V Portfolio Cull Every Brand Owner Must Run Before 2030
Most PPWR obligations ask you to change how a pack is made — its recyclability grade, its recycled content, its labelling. Article 25 is different: it says certain packaging formats may not be placed on the EU market at all, regardless of how well they are made. From 1 January 2030, six categories of single-use packaging listed in Annex V of Regulation (EU) 2025/40 become illegal to sell. For brand owners, retailers, HORECA operators and cosmetics houses, this is not a design tweak — it is a portfolio cull, and the SKUs it removes need reformatting or substitution decisions taken in 2026 and 2027, not in the last quarter before the deadline.
What Article 25 Actually Says
Article 25 introduces a hard prohibition: economic operators shall not place on the market the packaging formats listed in Annex V. It is a market-access ban, not a fee, a grade or a labelling requirement. There is no "grade C" version of a banned format, no eco-modulation surcharge that buys you the right to keep selling it, and no phase-down curve — on 1 January 2030 the format is simply gone. Unlike the recyclability regime in Article 6 or the recycled-content targets in Article 7, which set a performance bar that packaging must clear, Article 25 removes whole constructions from the market irrespective of their recyclability or recycled content. A perfectly recyclable, high recycled-content shrink film used to bundle multipack cans is still banned if it falls within Annex V point 1.
The obligation lands squarely on the party placing the packaged product on the market — in practice the brand owner or, for imported own-brand goods, the importer treated as the manufacturer under the June 2026 Commission guidance. Retailers placing private-label products, and HORECA operators serving food and drink for on-premises consumption, are directly in scope. This is one of the few PPWR duties where the burden cannot be pushed down to the converter: the converter can make a compliant alternative, but only the brand owner decides whether the banned format leaves the range.
The Six Banned Formats in Annex V
Annex V lists six restricted formats. Read them as a checklist against your live SKU list, because each one maps to a specific, recognisable pack that is on shelves today.
| Annex V point | Banned format | Who it hits |
|---|---|---|
| Point 1 | Single-use plastic grouped (multipack) packaging bundling goods sold in bottles, cans, tins, pots, tubs and packets — e.g. shrink film around a can multipack | Beverage, food and household brand owners; retailers |
| Point 2 | Single-use plastic packaging for prepacked fresh fruit and vegetables below 1.5 kg | Fresh-produce brands, growers, grocery retailers |
| Point 3 | Single-use plastic packaging for food and beverages filled and consumed on-premises in the HORECA sector | Restaurants, cafés, hotels, catering |
| Point 4 | Single-use plastic single-portion packaging for condiments, preserves, sauces, coffee creamer, sugar and seasoning in HORECA | HORECA operators and their condiment suppliers |
| Point 5 | Single-use packaging for cosmetic, hygiene and toiletry products in the accommodation sector (hotel miniatures, typically under 50 ml / 100 g) — regardless of material | Hotels, cosmetics and personal-care brand owners |
| Point 6 | Very lightweight plastic carrier bags (below 15 microns), except where required for hygiene or to prevent food waste | Grocery retailers, produce departments |
Two features make this list sharper than it first looks. Point 5 bans the hotel miniature regardless of material — switching a shampoo mini from plastic to a coated-paper sachet does not exempt it; the format itself is prohibited in the accommodation context. And points 3 and 4 are not a material problem you can engineer away with a better polymer: they push the entire on-premises HORECA serving model toward reusable systems under Article 29 and the reuse targets in Article 43.
The 5% Line: A Scope Rule, Not a Safe Harbour
The most misunderstood detail in Annex V is the 5% plastic threshold. For points 1 to 4, paper-based packaging containing not more than 5% plastic by weight is outside the format ban. Packaging teams keep reading this as a design target — "keep the plastic under 5% and we are safe." It is not a safe harbour; it is a scope rule that decides whether your pack is even assessed as "plastic packaging" for the purposes of these four points.
The trap is threefold. First, the 5% carve-out does not apply to points 5 and 6 at all — a hotel miniature or a very lightweight carrier bag is caught whatever its composition. Second, a pack that drops below 5% plastic to escape Article 25 still has to satisfy every other PPWR obligation: the Article 6 recyclability grade under Annex II, the Article 10 and Annex IV minimisation criteria, and the Article 39 Declaration of Conformity under Annex VIII. Escaping the format ban does not exempt you from the recyclability and minimisation regime. Third, the 5% has to be substantiated with real composition data per SKU, which most portfolios cannot currently produce on demand. Treat 5% as a line you must be able to prove, not a line you can assume.
Where Brand Owners Get Caught
Multipack and grouping film (Point 1)
Collation shrink film around beverage multipacks, and the plastic banding on canned-goods trays, is the highest-volume casualty. The exemption for grouped packaging genuinely necessary for handling and logistics is narrow and does not cover retail-facing multipacks whose purpose is to sell four, six or twenty-four units together. This obligation also interacts with Article 24: even where a grouping format survives, the empty-space and minimisation rules keep tightening around it. Brand owners should expect to migrate multipacks to board wraps, clip carriers or fully reusable crates well ahead of 2030.
Fresh produce under 1.5 kg (Point 2)
Flow-wrapped cucumbers, film-lidded berry punnets, netted citrus and pillow-bagged salad below 1.5 kg are directly in scope. The regulation allows Member States to keep plastic where a specific need can be demonstrated — for example a genuine risk of accelerated deterioration or water loss for sensitive produce — but the default is no plastic. Produce brands need a variety-by-variety assessment now, because the compliant answer (loose sale, paper bands, fibre punnets, or a demonstrated exemption) differs by crop and cannot be decided at portfolio level.
HORECA on-premises and single-serve condiments (Points 3 & 4)
For anything filled and consumed inside a restaurant, café or hotel, single-use plastic service packaging is out, and the little jam pots, UHT creamer capsules, ketchup sachets and sugar sticks on the table are out as a distinct category. This is where Article 25 stops being a packaging-swap exercise and becomes an operating-model change: reusable tableware, bulk dispensers and refill formats replace the single-serve model. Condiment and dairy brands that supply HORECA should be redesigning around bulk and dispensed formats, not searching for a compliant sachet.
Hotel miniatures — regardless of material (Point 5)
The accommodation-sector ban on single-use miniatures is material-agnostic, which catches the obvious substitution routes. Fixed wall-mounted dispensers and returnable refillable bottles are the compliant direction for shampoo, conditioner and shower gel. Cosmetics and personal-care brand owners whose hospitality channel relies on branded minis need a hospitality-line strategy that assumes the mini is gone by 2030.
Very lightweight carrier bags (Point 6)
Bags below 15 microns are banned except where needed for hygiene or to avoid food waste — the classic loose-produce roll bag being the main survivor, and only where genuinely justified. Retailers should audit every checkout and produce-aisle bag SKU against the hygiene and food-waste tests rather than assume continuity.
How the Format Bans Interlock With the Rest of PPWR
Article 25 does not sit alone. The formats it removes are exactly the ones that also struggle under Article 24 (empty space in grouped and transport packaging), Article 10 and Annex IV (minimisation of weight and volume), and the reuse obligations of Articles 29 and 43 that push HORECA and transport packaging toward refillable systems. Whatever replaces a banned format must itself clear the Article 6 recyclability grade in Annex II and be documented in the Article 39 Declaration of Conformity under Annex VIII. In other words, you cannot solve Annex V in isolation: every substitution decision is simultaneously a recyclability, minimisation and documentation decision. Running these checks in one place, per SKU, is the difference between a controlled 2026–2029 transition and a scramble. Our PPWR compliance software models the format ban alongside the recyclability grade and Declaration of Conformity for each reference so the trade-offs are visible in a single view.
Action Plan for Brand Owners and Retailers
- Screen the full SKU list against the six Annex V points — tag every reference as in-scope, exempt, or needs-assessment. Multipack film, sub-1.5 kg produce packs, HORECA single-serve items, hotel minis and sub-15-micron bags are the priority buckets.
- Substantiate the 5% line where you rely on it — for points 1 to 4, capture real per-SKU composition data proving paper-based packaging stays at or below 5% plastic by weight; treat it as evidence you must hold, not an assumption.
- Separate format bans from material swaps — for points 3, 4 and 5, plan reusable, bulk, dispensed or refillable operating models rather than a like-for-like single-use replacement, because the format itself is prohibited.
- Run a produce assessment crop by crop — decide where a demonstrated deterioration or food-waste exemption is defensible and where loose sale or fibre alternatives are the answer.
- Re-check every replacement against Article 6, Article 10 and Article 39 — confirm the new format holds an Annex II recyclability grade, passes minimisation, and is captured in the Declaration of Conformity. Start from a PPWR Declaration of Conformity template so the substitution is documented from day one.
- Sequence the transition across 2026–2029 — supplier qualification, line trials and reusable-system rollouts for HORECA and hospitality take years, not months; the 1 January 2030 date is a placing-on-market cut-off, not a sell-through deadline.
How PPWR Connect Helps
Article 25 turns your product range into a compliance question that only the brand owner can answer, and it interlocks with recyclability, minimisation and Declaration of Conformity duties that all fall due first on 12 August 2026. PPWR Connect lets brand owners, retailers and importers inventory every packaged SKU, flag the ones caught by each Annex V point, substantiate the 5% paper-based threshold with real composition data, and model the compliant replacement against its Annex II recyclability grade and Annex VIII Declaration of Conformity in the same place. You can start by running the affected part of your portfolio through our free PPWR assessment to see which formats are exposed and what the substitution path looks like.