Reusable packaging mandate and its impact on snack bars

A coffee-to-go cup in the morning, currywurst at lunchtime, a burger on the way home: for snack bars, takeaway packaging is part of everyday business. The impact of the reusable packaging mandate on snack bars therefore extends beyond purchasing packaging. It affects the counter, point-of-sale system, staff workflows, returns and communication with customers.

Since January 1, 2023, many food service businesses have been required to offer a reusable option in addition to certain single-use packaging when selling food and drinks to take away. For snack bar operators, a realistic assessment is particularly important: Which products fall within the scope, which solution suits their business, and where do single-use packages remain the practical choice?

Reusable packaging mandate: correctly assessing the impact on snack bars

The reusable packaging offer requirement is regulated in the Packaging Act. It applies to retailers who serve food or drinks to end customers. It is not relevant whether a business considers itself a restaurant, kiosk, café or snack bar. What matters is which packaging is used for which product.

For drinks in single-use beverage cups, a reusable alternative must generally be offered. This includes coffee, soft drinks and other drinks to take away. For food, the requirement for single-use plastic food packaging applies if the food is ready to eat, can be eaten without further preparation and is typically consumed directly from the packaging. Typical examples include plastic menu trays, soup cups, salad boxes or burger boxes.

The material is important. Pure paper and cardboard packaging for food is not automatically subject to the reusable packaging offer requirement. However, coatings or plastic components can change the legal classification. Different requirements apply to beverage cups. Therefore, anyone purchasing cups, lids or trays should clearly document material specifications and product details. Packaging that appears environmentally friendly is not necessarily excluded from the scope by operation of law.

The reusable option must be available for the same type of food or drink. It must not be offered on less favourable terms than the single-use option. A deposit is permitted and usually makes sense in everyday practice, as it provides financial security for returns and circulation. However, the actual product price for the reusable packaging must not be set higher than for the comparable single-use packaging.

Which snack bars are affected - and what exceptions apply?

Not every small sales stand has to introduce a full reusable packaging system. An exception applies to businesses with no more than five employees and a sales area of no more than 80 square metres. They do not have to provide their own reusable containers. Instead, they must allow customers to have their own reusable containers filled.

This exception is particularly relevant for very small snack bars, kiosks, bakery branches or mobile food vans. However, both conditions must be met. Anyone with more than five employees or operating a larger sales area cannot rely solely on the small size of their business. The situation must also be carefully examined for businesses with multiple branches.

Even exempt businesses have information obligations. Customers must be able to clearly see that their own suitable containers can be filled. A small, clearly legible sign at the counter is often sufficient, rather than a lengthy explanation. What matters is that the team knows the rules and that implementation works in the service.

Clear procedures are needed for hygienically sensitive products. Customers' own containers should not sit on surfaces where open food is prepared. Handing them over on a tray or at a designated collection point is practical. This reduces the risk of cross-contamination without unnecessarily slowing down sales.

What actually changes in daily operations

The biggest challenge is rarely the reusable box itself. It lies in the process. A business needs a clear workflow from sale and deposit collection to return. Without this process, peak times bring follow-up questions, incorrect till entries and unnecessary arguments with customers.

First, it should be decided whether to use an in-house reusable system or an external pool system. In-house containers offer more control over design, inventory and returns. However, this also means that cleaning, storage and replacement must be organised. Pool systems can make returns easier at other participating locations, but they incur ongoing fees and tie the business to the provider's specifications.

For many snack bars, a combination makes sense: reusable cups for hot drinks and reusable trays for individual standard dishes, while suitable single-use packaging is used for other products. A filled roll, chips or a dry baked good have different requirements than a hot pasta dish with sauce. Not every product needs to be sold in the same container for reasons of functionality, delivery route or hygiene.

The till should clearly show the deposit and return options. Staff need short, clear instructions: Which items are available in reusable packaging? What is the deposit? Where are returned containers collected? When are they washed or handed over to the system partner? These points should be included in a simple set of work instructions, not just covered in an oral briefing.

The space required is also often underestimated. Clean reusable containers, returns and lids must not be stored haphazardly next to single-use cups or food packaging. A designated area for clean stock and a separate return container create order. Especially when storage space is limited, it pays to plan the required circulation volume based on sales figures and return times.

Single-use remains relevant for many sales situations

The reusable packaging mandate is not a general ban on single-use packaging. Snack bars may continue to use single-use products, provided they offer the required reusable alternative or fall under an exception. For many applications, single-use solutions remain economically and hygienically practical.

This is particularly true for delivery orders, during periods of highly fluctuating customer numbers, at events or for food with long transport times. A sturdy, food-safe box must close tightly, regulate heat and moisture appropriately and be safely stackable during transport. For burgers, snacks, baked goods or cold food, paper, cardboard and other fibre-based solutions can be a practical addition.

The unit purchase price should not be the only deciding factor. A paper bag that is too thin, a cup that becomes soggy or an unsuitable tray leads to complaints and increased consumption. For daily requirements, format, material thickness, grease and moisture resistance and availability in suitable pack sizes are important. Using standardised packaging also simplifies reordering and inventory management.

Calculate costs realistically instead of just comparing unit prices

Reusable packaging can be economical with regular use, but not automatically. The initial purchase price must be added to deposit management, washing, staff time, shrinkage and storage space. This is weighed against potential savings on single-use items and a visible offer for environmentally conscious customers.

A useful calculation therefore considers the entire circulation. How many times is a container likely to be reused? How much does each wash cost? How many containers are not returned? How much time is spent at the till and collecting returns? Only then can it be assessed whether an in-house system, a pool provider or a lean solution using customers' own containers suits the business.

With single-use packaging, it pays to look at the price per unit again, not just the price per carton. Larger packs often reduce costs, provided storage space and actual consumption are suitable. An excessively large supply ties up capital and can become impractical for seasonal ranges.

Implementing the reusable packaging mandate practically in snack bars

The easiest start is a brief inventory check. First, check which drinks and foods are served in which packaging. Categorise the items by material and application. Then it will be possible to determine which products need a reusable alternative and where single-use packaging can continue to be used appropriately.

First test the reusable offer with a few highly popular items. A clearly labelled reusable coffee cup and a suitable tray for a standard dish are often easier to manage than an extensive range from day one. Monitor the return rate, washing effort and customer questions over several weeks.

Clear communication prevents friction. The price of the food or drink, the deposit and the return options should be clearly visible at the counter. Staff should not treat reusable packaging as a special case, but as one of two normal packaging options. The simpler the process appears, the more readily it will be accepted.

The right packaging decision does not come from using as many materials or systems as possible, but from a process that suits the counter, the range and actual customer behaviour. Those who introduce reusable packaging systematically and select single-use packaging based on its function will better balance service, hygiene and costs in daily sales.