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Own containers and reusable take-away packaging: the PPWR reuse and single-use rules and their dates

Last checked7 October 2026
KeeperOpen — keeper wanted
StatusFrom 12 February 2027

The short version

Two Bulgarian reports of 7 October 2026 describe rules said to be arriving in Bulgaria as "new European rules": from 12 February 2027 traders must let customers who want to buy food in their own containers; from 2028 take-away establishments must offer reusable packaging; by 2030 the small single-use bottles in hotel bathrooms are to go and single-use plastic packaging for small quantities of fruit and vegetables is to be restricted. The three dates survive contact with the Regulation: they are Article 32, Article 33 and Article 25(1) with Annex V of Regulation (EU) 2025/40. What the Regulation does not do is the part to keep separate — no dispenser duty, no named alternative material, and the micro-enterprise exemption that the reports leave out applies to the reusable offer only, not to the own-container duty.

How this page is sourced. The dates, the actors and the exemptions below are read from Regulation (EU) 2025/40 on EUR-Lex on 7 October 2026 — Article 25, Article 28, Article 32, Article 33, Annex V and the definitions in Article 3(1). The Commission's PPWR FAQ (2nd edition, August 2026) is official too, and describes itself as not binding law. Everything that reached us only through the Bulgarian press of 7 October 2026 is marked press, and both reports are read in full; neither cites the Regulation or an article number. Two further reports of the same story (bTV Новините, novini247) could not be opened at all and are not relied on here.

What applies, and when

The Regulation has applied since 12 August 2026 (Article 71), but the three duties on this page carry their own, later dates. All three are in the text of the Regulation rather than in a national implementing measure, so none of them waits for a Bulgarian act.

Own containers — Article 32
By 12 February 2027, final distributors in the HORECA sector that make hot or cold beverages or ready-prepared food available in take-away packaging must provide a system for consumers to bring their own container to be filled.
Reusable take-away packaging — Article 33(1)
By 12 February 2028, those final distributors must give consumers the option of obtaining the products in reusable packaging within a re-use system. Micro-enterprises are exempt (Article 33(4)).
Single-use formats — Article 25(1) with Annex V
From 1 January 2030, economic operators must not place on the market the packaging formats and uses listed in Annex V. On this page that means the hotel miniatures (point 5) and single-use plastic packaging for less than 1,5 kg of pre-packed fresh fruit and vegetables (point 2).
The guidelines that will explain it — Article 25(6)
By 12 February 2027 the Commission must publish guidelines explaining Annex V, including a non-exhaustive list of fruits and vegetables excluded from point 2. Until they exist, the scope of the bans is the Commission's to clarify, not ours.
What the Bulgarian reports date
Press, 7 October 2026: "from 12 February next year" for food in customers' own containers, "from 2028" for reusable take-away containers, and 2030 for hotel dispensers. Same three dates; no article numbers, and no Bulgarian act cited.
Two dates, one day apart in the calendar, two different duties. The own-container obligation bites on 12 February 2027; the reusable-offer obligation a year later, on 12 February 2028. Bulgarian reporting has run the two together since the story appeared, and a business that reads only "2028" will be a year late on the first one.

Own containers: Article 32

This is the provision behind the Bulgarian headline. The title of Article 32 is "Refill obligation for the takeaway sector", and it opens with a date, not with a principle:

The Regulation, verbatim

"By 12 February 2027: (a) final distributors that conduct their business activity in the HORECA sector and that make available on the territory of a Member State hot or cold beverages in take-away packaging shall provide a system for consumers to bring their own container to be filled; (b) final distributors that conduct their business activity in the HORECA sector and that make available on the territory of a Member State ready-prepared food in take-away packaging shall provide a system for consumers to bring their own container to be filled."

No penalty for bringing your own
Article 32(2): where consumers bring their own container, the products must be offered at no higher cost and under no less favourable conditions than the sales unit of the same product in single-use packaging. Both Bulgarian reports make the matching point that no customer is obliged to bring one (press).
Signage is part of the duty
Article 32(2), second subparagraph: final distributors must inform consumers at the point of sale, through clearly visible and legible information boards or signs, that they may bring their own refillable container.
There is no size exemption in the article
We read Article 32 in full on 7 October 2026: it has no micro-enterprise carve-out and no sales-area threshold. Whoever is a final distributor in the HORECA sector serving take-away in one of these products is in scope. Compare Article 33, which does have one.
You may still refuse a bad container
Article 28(4), on refill generally: an operator may refuse to refill a container provided by the end user if the user does not comply with the refill rules it has communicated — in particular if the operator considers the container unhygienic or unsuitable for the sale of food or drink — and bears no liability for hygiene or food-safety issues arising from the use of the end user's container.
The hygiene conditions are yours to publish
Article 28(1): operators offering refill must inform end users of the types of container that can be used, the hygiene standards for refill, and the end user's own responsibility for health and safety. Those "rules for refill" must be kept up to date and displayed on the premises or otherwise provided.
Where Bulgaria's food-safety worry sits. The Bulgarian Food Safety Agency (БАБХ) is reported as concerned that improperly used or insufficiently clean personal containers could spread infection, and the reports say the national safety requirements still have to be settled before the rule applies (press). The EU text answers one half of that on its own account: Article 28(4) gives the operator the right to turn a container away and removes its liability for what the customer's container carries. What Bulgaria adds on top of that is not something we have found in writing.

Reusable take-away packaging: Article 33

A year after the own-container duty comes the harder one — the establishment itself has to have reusable packaging and a system to go with it.

Article 33(1)
By 12 February 2028, final distributors in the HORECA sector that make hot or cold beverages or ready-prepared food available in take-away packaging in a Member State "shall give consumers the option of obtaining the products in re-useable packaging within a system for re-use". This is the item the Bulgarian reports summarise as "from 2028 the establishments will have to offer reusable containers" (press).
Same price, same conditions
Article 33(3): the reusable option must be offered at no higher cost and under no less favourable conditions than the single-use equivalent. Article 33(2): visibly inform consumers at the point of sale.
The micro-enterprise exemption — Article 33(4)
Final distributors that fall within the definition of a micro-enterprise in Recommendation 2003/361/EC as applicable on 11 February 2025 are exempt from this Article. In short, that is a business with fewer than 10 employees and a turnover or balance-sheet total of at most €2 million. Read the exemption as scoped to Article 33: it does not touch Article 32.
From 2030, a 10% aspiration — Article 33(5)
"From 2030, final distributors shall endeavour to offer 10% of products for sale in a reusable packaging format." Same softer verb the transport-packaging targets use: it is not the 2028 option duty restated, and it is not a hard quota.
Member States may go further — Article 33(6)
Under the conditions in Article 51, a Member State may set targets for economic operators going beyond that 10%, where higher targets are necessary to reach the packaging-waste targets in Article 43.

The Bulgarian reports add that similar systems already work in other European countries, and give one example: in Italy, consumers may buy food in their own boxes if those are clean, intact and fitted with a lid (press). That is a practice, not the Regulation's wording — but it is a useful picture of what a shop's "rules for refill" under Article 28(1) tend to look like in practice.

Hotel miniatures and small fruit and vegetables: Annex V

The 2030 items are bans on formats rather than reuse duties, which changes what a business has to do: stop buying the format, rather than build a system.

The mechanism — Article 25(1)
"From 1 January 2030, economic operators shall not place on the market packaging in the formats and for the uses listed in Annex V." Both items below live in that annex, so the same date and the same actor apply to each.
Hotel and accommodation miniatures — Annex V, point 5
The restricted use is "single-use accommodation sector packaging intended for an individual booking": single-use packaging for cosmetics, hygiene and toiletry products for use in the accommodation sector, intended for an individual booking only and to be discarded before the next guest arrives. The annex's illustrative formats are shampoo bottles, hand and body lotion bottles, sachets around bar soap.
What the reports call a dispenser duty
Press, 7 October 2026: by 2030 the use of large refillable dispensers in bathrooms becomes mandatory for all places of accommodation, and small single-use shampoo and shower-gel bottles are to go. The dispensers are the reports' framing, not the Regulation's text — what the Regulation bans is the single-use format. A dispenser, a soap bar without packaging, or anything else that avoids the banned format all do the same job under the text.
Small fruit and vegetables — Annex V, point 2
Restricted use: "single-use plastic packaging for less than 1,5 kg pre-packed fresh fruit and vegetables". Illustrative formats: nets, bags, trays, containers. Member States may set exemptions where there is a demonstrated need — to avoid water loss or turgidity loss, microbiological hazards or physical shocks, oxidation, or where there is no other way to avoid commingling of organic and non-organic produce without disproportionate cost.
Cardboard and reusable bags are the reports' suggestion
Press: single-use packaging for fruit and vegetables, especially small quantities, is to be restricted, and "as an alternative, cardboard packaging or reusable bags can be used". The Regulation names no substitute — it restricts the plastic format. Dir.bg also gives a consumer-facing reason the Regulation does not state: prepacked produce can hide spoilage that cannot be seen before purchase.
The micro-enterprise derogation does not reach these two
Article 25(4) lets Member States allow micro-enterprises to keep placing on the market the formats in Annex V point 3 — the ban on single-use plastic packaging for food and drink filled and consumed on the premises in the HORECA sector. It is written for point 3, not for point 2 or point 5.
What a hotel can still do — the FAQ
FAQ, chapter XII question 6, on the miniatures: the Regulation does not define "cosmetics, hygiene and toiletry product", and exempts neither miniatures available on request nor those sold at the premises — the focus is packaging "intended for an individual booking". It adds that only the packaging is banned, not the product, which may still be made available without packaging.

Who is bound — and who is not

Every duty on this page attaches to a final distributor, or to an economic operator placing the banned formats on the market. The Regulation defines the first term itself:

Article 3(1), point (21) — final distributor
"the natural or legal person in the supply chain that delivers packaged products, including through re-use, or products that can be purchased through refill, to the end user". A café counter, a bakery, a take-away window, a food shop with a hot counter: the person the customer is standing in front of.
Article 3(1), point (35) — HORECA sector
"Accommodation and Food Service Activities according to NACE Rev. 2". The FAQ adds, for the related bans, that the decisive element is that meals and beverages fit for immediate consumption are offered at the facility, not the type of facility.
Article 3(1), point (3) — take-away packaging
"service packaging filled at attended points of sale with beverages or ready-prepared food that are packaged for transportation and immediate consumption at another location without the need for any further preparation and are typically consumed from the packaging". Two things follow: it is filled at the point of sale, and it is not the parcel a webshop ships.
Not bound: the parcel sender
Nothing in Article 32, Article 33 or the two Annex V points concerns transport packaging or e-commerce packaging. A seller who ships goods to consumers in a cardboard box is outside all of it. For the duties that do reach that seller, see the PPWR reuse targets and void fill and minimisation.
Not automatically bound: the establishment that only serves in
Article 32 and Article 33 both hang on making products available in take-away packaging. Annex V point 3, by contrast, is about packaging for food and drink filled and consumed on the premises — a different item, a different ban, and not the subject of this page.

Does this reach a one-person online shop?

Normally not. If your business posts parcels, the nearest thing to an own-container rule you have to think about is the customer's right to return the goods. There is no duty in Article 32 or Article 33 to accept anything a customer sends you, and no reuse system to join in order to keep selling online.

The exception is narrow but real, and it is about what you sell, not how small you are:

You also sell take-away food or drink
Then you are a final distributor in the HORECA sector for those sales, and Article 32 applies to you from 12 February 2027 — the own-container system, the same price and conditions, and the sign at the point of sale. We found no size carve-out in the article, so a one-person counter is not exempt from it.
You are a micro-enterprise — what that buys you
An exemption from Article 33 only: if you fall within Recommendation 2003/361/EC (in short, fewer than 10 employees, turnover or balance sheet at most €2 million), you are not required to offer the reusable-packaging option from 12 February 2028. It does not exempt you from the own-container duty a year earlier.
You run accommodation
From 1 January 2030 the single-use cosmetic, hygiene and toiletry packaging you offer for an individual booking is a format you must not place on the market (Annex V, point 5). What you buy instead is your choice; the ban names no product or format of replacement.
You sell produce online in small plastic trays
From 1 January 2030, single-use plastic packaging for less than 1,5 kg of pre-packed fresh fruit and vegetables is on the Annex V, point 2, list. That one can reach an online grocer, so it is worth checking against the Commission's guidelines when they appear — due by 12 February 2027 under Article 25(6). Member States may also carve out cases where the packaging is needed to avoid spoilage or commingling.
Country angle. The reports behind this page are Bulgarian, and the authority they name as controlling the ordinance is the Ministry of Environment and Water (press — stated in the passage on customers' own containers). The Bulgarian EPR side of packaging law is a separate subject and is on the Bulgaria desk.

The dates as reported, against the Regulation

The Bulgarian reports give no article numbers, so the useful thing we can do is put the two side by side. Four of the reported items check out against the text; the rest are the reports' own framing or a national question the Regulation leaves open.

Reported, 7 October 2026 (press)What the Regulation says
Customers may buy food in their own boxes and containers from 12 February next year (2027), and nobody is obliged to bring their ownConfirmed. Article 32: by 12 February 2027, HORECA final distributors must provide a system for consumers to bring their own container; no higher cost, no less favourable conditions. The option is an option — no consumer duty exists in the text either
From 2028, establishments offering take-away food must also offer containers for reuseConfirmed, with one addition. Article 33(1) dates it to 12 February 2028; Article 33(4) exempts micro-enterprises — a carve-out absent from the reports
By 2030, large refillable dispensers become mandatory in hotel bathroomsHalf-confirmed. From 1 January 2030 the single-use formats (shampoo bottles, lotion bottles, soap sachets) may not be placed on the market (Article 25(1) with Annex V, point 5). No dispenser requirement appears in the text
Single-use plastic packaging for small quantities of fruit and vegetables is to be replaced by cardboard boxes or reusable bagsPartly. Annex V, point 2 restricts single-use plastic packaging for less than 1,5 kg of pre-packed fresh fruit and vegetables from 1 January 2030. The alternatives are the report's: the Regulation names none
Own containers have existed in Bulgarian law since 2019, under rules introduced when Bulgaria transposed a European directiveNot in the Regulation, and the report names neither the directive nor the rule. We could not establish what changes in Bulgarian law on 12 February 2027 as a result — see below
БАБХ sees an infection risk in unclean personal containers, and national food-safety requirements must be settled before the rule appliesNational, and unsettled. At EU level Article 28(1) and (4) put the hygiene rules and the right to refuse an unsuitable container on the operator. We found no Bulgarian text settling the national detail
The Ministry of Environment and Water is the control authority under the ordinanceNational. Not a statement the Regulation makes — the reports say it in their passage on customers' own containers, not in the passage on the 2030 design and single-use rules

What we could not establish

What actually changes in Bulgaria on 12 February 2027
Dir.bg states that the possibility for consumers to use their own containers has been provided for in Bulgarian law since 2019, under rules introduced when the country transposed a European directive (press). Neither report says which directive or which rule, and we have found no Bulgarian act that explains the difference between the 2019 rule and Article 32. So we cannot say whether 12 February 2027 is a new right in Bulgaria or an EU duty bolted onto a national rule that already existed.
The Bulgarian implementing act
We have not found a Bulgarian ordinance, or a draft, carrying the take-away items, the hotel item or the fruit-and-vegetable item. The Regulation is directly applicable, so a national act is not what makes the duty bite — but the reports describe national requirements still being written, and we could not see them.
Whether the two unfetchable reports add anything
bTV Новините and novini247 report the same story on the same day, and both refused our requests (HTTP 403) on 7 October 2026. This page therefore rests on two Bulgarian reports, not four, and we say so rather than cite what we have not read.
Which Member States will use the exemptions
Annex V, point 2, lets Member States exempt cases where there is a demonstrated need; no Member State's list is published yet, and the Commission's guidelines (due 12 February 2027) will carry the non-exhaustive list of fruit and vegetable types excluded from the ban.
How "an individual booking" is drawn
The FAQ notes the Regulation does not define "cosmetics, hygiene and toiletry product" and that the Commission is to explain Annex V further by 12 February 2027. Whether, for example, a miniature offered on request at reception is in scope is not settled by the text we read.

Known traps

"From 2027 I must fill whatever container a customer hands me"

Not quite. Article 28(4) lets the operator refuse a container the end user brings if it does not comply with the published refill rules — in particular where the operator considers it unhygienic or unsuitable for food or drink — and the operator bears no liability for hygiene or food-safety issues arising from the customer's container.

"The 2027 rule and the 2028 rule are the same rule"

They are two articles. Article 32 (own containers) bites 12 February 2027; Article 33 (reusable packaging offered by the business) bites 12 February 2028. Only the second one carries the micro-enterprise exemption.

"Hotels must install dispensers"

What the Regulation bans from 1 January 2030 is the single-use format for cosmetic, hygiene and toiletry products intended for an individual booking. A dispenser, a naked soap bar, or a product sold unpackaged all satisfy that; the dispenser is the press's shorthand, not a duty.

"Cardboard boxes for fruit are now mandatory"

The reports say cardboard boxes or reusable bags are the alternative; the Regulation restricts the plastic format and names no replacement. Buying cardboard boxes is a choice you are free to check against cost and food-contact requirements — it is not the wording of Annex V.

"This is a new EU rule arriving in 2027"

The instrument is not new: Regulation (EU) 2025/40 has applied since 12 August 2026 (Article 71), and these are later compliance dates inside it. Anyone presenting the 2027 date as a Bulgarian or brand-new EU rule has the wrong instrument in mind.

"I'm a one-person shop, so none of this applies"

True for a parcel operation. Wrong for a take-away counter: Article 32 has no size exemption, so the own-container duty lands on the smallest HORECA final distributor. The micro-enterprise exemption is real, but it is written into Article 33 alone.

Sources

One official text, one official Q&A and two Bulgarian press reports. The Regulation is cited by article for everything it decides; the two reports are cited only where they are the sole support, and marked press. Neither report names the Regulation, an article or a Bulgarian act, so none of their dates should be quoted at an authority without checking against Regulation (EU) 2025/40 first.

  1. Regulation (EU) 2025/40 (PPWR) — EUR-Lex The governing text. Read on 7 October 2026 for: Article 3(1), points (3), (21) and (35), defining take-away packaging, final distributor and the HORECA sector; Article 25(1) and (4) and (6) on the Annex V bans, the micro-enterprise derogation for point 3 and the guidelines due by 12 February 2027; Article 28(1), (2), (3) and (4) on refill rules, hygiene, the right to refuse an unsuitable container and the absence of liability; Article 32 in full on the own-container duty from 12 February 2027; Article 33 in full, including the micro-enterprise exemption and the 10% "endeavour" from 2030; Article 71 on application from 12 August 2026; and Annex V, points 2 and 5, with their restricted uses, illustrative formats and exemptions. Other articles and the FAQ citations below trace to the Commission's own document
  2. European Commission — PPWR Frequently Asked Questions, 2nd edition (KH-01-26-068-EN-N), August 2026 Official: DG ENV Unit B01, and mirrored and described here. Read for this page in chapter XII ("Bans and the use of certain packaging"): question 1 on the guidelines to explain Annex V by February 2027 and the review of the bans by 2032; question 2 on less than 1,5 kg of unprocessed fresh fruit and vegetables not being allowed to be prepacked; question 6 on miniature cosmetics, "individual booking" and the point that only packaging is banned, not the product; and question 8, which says that where a hotel delivers food and drink outside its premises the Annex V point 3 ban does not apply but the refill and re-use obligations in Articles 32 and 33 do. It states in its own disclaimer that it reflects the views only of its authors and is not binding law
  3. Dir.bg — Нови правила за опаковките: Ще можем да купуваме храна в лични кутии Bulgarian media, 7 October 2026, Irina Veleva. Read in full. Used as press for: traders having to let customers buy food in their own boxes and containers from 12 February next year, and consumers not being obliged to bring their own; БАБХ's concern about infection risk from improperly used or insufficiently clean personal containers, with national safety requirements to be settled before the rule applies; the statement that own containers have been provided for in Bulgarian law since 2019 under rules introduced when transposing a European directive (the directive is not named); control under the ordinance lying with the Ministry of Environment and Water; the 2028 reusable take-away containers, with Italy as an example where own boxes must be clean, intact and fitted with a lid; the restriction on single-use packaging for fruit and vegetables, especially small quantities, with cardboard packaging or reusable bags named as alternatives; and the hotel miniatures being replaced by larger refillable dispensers, mandatory from 2030. It also carries the empty-space, double-wall and e-commerce filler items, which belong to the minimisation note. Cites no regulation and no article number
  4. DUNAVMOST — Забраняват излишния въздух в опаковките и двойните дъна Bulgarian media, 7 October 2026, Petar Simeonov. Read in full. Second, independent report of the take-away items, and the only one of the two to place the hotel dispenser item under its own heading. Used as press for: traders in Bulgaria being obliged from 12 February next year to allow customers to buy food in personal containers; the food-safety question for personal containers being finally decided at national level, with the Ministry of Environment and Water as control authority under the ordinance while БАБХ raises the infection risk; from 2028 take-away establishments having to provide reusable containers, with Italy named (containers to be intact, clean and fitted with a tight-fitting lid); single-use plastic packaging for small fruit and vegetables to be replaced by cardboard boxes or reusable bags; and, by 2030, the use of large refillable dispensers in bathrooms becoming mandatory for all places of accommodation, with Bulgarian producers already offering such solutions. Cites no regulation and no article number
Two reports we did not read. bTV Новините and novini247 carry the same story of 7 October 2026, and both returned HTTP 403 to us on the day. Dir.bg attributes its own opening sentence to bTV, so the two are related; we have not treated the bTV or novini247 texts as sources at all. If you can supply either, the Discord is the place.

Help us keep this page honest

What this page most needs is not another reading of the Regulation. It is the Bulgarian side: the national rules for personal containers the reports say are still being written, and any Bulgarian act that explains the 2019 provision Dir.bg mentions. If you run a take-away counter or a small hotel, the other useful thing is what your authority or your supplier actually told you — in writing — about the 2027 and 2030 dates. And the two unfetchable reports above would let us check the parts of this story that rest on two articles rather than four.