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Reusable Packaging Mandate in Catering: What Businesses Need to Do Now

If you sell coffee in paper cups, bowls, salads, or hot dishes to take away, you must take the reusable packaging requirement for the food service industry into account in your daily business. This does not mean that single-use packaging will disappear completely. However, it requires a suitable reusable alternative for certain to-go offers. The key is not only the legal text, but a process that works quickly at the counter, remains hygienic, and is easy for customers to understand.

For cafés, snack bars, bakeries, restaurants, and caterers, this raises one question in particular: Which types of packaging are affected, what exception applies to your own business, and how can reusable packaging be offered without unnecessary effort?

Reusable packaging requirement in the food service industry: Who it affects

The statutory reusable packaging requirement applies to businesses that offer food or drinks for immediate consumption in single-use plastic packaging or single-use drink cups. This includes, for example, coffee-to-go cups, salads in plastic containers, hot bowls with plastic lids, or ready-made meals in plastic-containing to-go containers.

The requirement applies to packaging for ready-to-eat food that is typically eaten immediately or on the go. The size of food containers also plays a role: the regulation generally applies to containers up to three liters. For drinks, single-use cups are affected, even if they are made of paper or cardboard and have a plastic coating. Lids should always be taken into account when making your own assessment, but they do not determine the basic classification of the cup on their own.

Not every type of packaging used in the food service industry is automatically affected. Plain paper bags for baked goods, uncoated paper bags, napkins, or classic cardboard packaging without any plastic content do not trigger the reusable packaging requirement. Products that are not intended for immediate consumption may also be assessed differently. A packaged delicatessen product intended for later consumption is not comparable to a freshly prepared lunch bowl.

In practice, it is worth checking your range not by product name, but by material and intended use. A cardboard burger box may be classified differently than a plastic container for fries or a coated cup for hot drinks. If you are unsure, you should document the material information on the packaging and have the specific application assessed.

Small businesses: How to make the right use of the exemption

There is a relaxation for small retail outlets. Businesses with no more than five employees and a sales area of no more than 80 square meters are not necessarily required to offer their own reusable containers or a deposit system. Both conditions must be met. Part-time employees are counted proportionally toward the number of employees.

However, the exemption does not completely exempt small businesses from the obligation to cooperate. Small businesses must allow customers to have their own brought-in containers filled with to-go food and drinks. They must also provide a clearly visible notice informing customers of this. A handwritten note behind the cash register is often not enough if customers only discover it when they ask.

Implementation requires a clear hygiene rule. The customer's container should not be passed over the work surface. It has proven effective to first fill the food or drink into a clean container belonging to the business and then transfer it into the customer's brought-in container. This keeps contact between the customer's container, the staff, and the serving area manageable. For drinks, a tray or a designated resting area can simplify the process.

Practical implementation of the reusable packaging requirement in the food service industry

Businesses that do not qualify for the small business exemption must make a reusable alternative available for the affected single-use items. This alternative must be suitable for the same purpose. If you offer single-use coffee cups, you need a reusable coffee cup. If you serve ready-to-eat food in plastic containers, you need a reusable solution for these foods.

Reusable packaging must not be more expensive than the comparable single-use option. A deposit is permitted because it is refunded upon return. The terms of sale must also not be worse. Offering reusable packaging only at certain times, only with a high minimum order, or only at a hard-to-reach pickup point is not a practical solution.

For many businesses, an external reusable packaging system makes sense. It reduces the effort required for collection, washing, and storage, but requires that returns are reliably organized. On the other hand, your own reusable containers may be worth it if returns are easy to plan and commercial washing facilities are available. Which option is more cost-effective depends on sales volume, locations, staff, and the typical customer base.

Before introducing it, the business should firmly establish four points:

  • Which drinks and foods will specifically have a reusable alternative?
  • Where will clean containers be stored, and where will returns be accepted?
  • How will the deposit, cash register, and refund be handled in the system?
  • What brief instructions will the staff receive for serving, collection, and hygiene?
These decisions should be recorded in a simple workflow plan at the cash register and serving area. Especially during peak times, no one should have to wonder which lid fits, how much deposit is charged, or where a returned cup belongs.

Single-use remains an option; material choice becomes more important

The reusable packaging requirement is not a general ban on single-use packaging. Customers may still choose single-use packaging as long as the business offers the required reusable alternative. For many retail outlets, single-use remains important: for spontaneous walk-in customers, larger orders, delivery business, or when return is not possible within a reasonable distance.

This is precisely why the choice of material is becoming increasingly important. Many applications that are not affected can often be sensibly covered with paper, kraft paper, or cardboard solutions. Paper bags for baked goods, bakery bags, carrier bags, sandwich bags, or suitable food boxes support clean off-premise sales and can reduce the proportion of plastic-containing packaging. The key is always that grease resistance, stability, temperature, and food contact are suitable for the product.

Choosing packaging solely because it gives an environmentally friendly impression is not enough. If a container becomes soggy when filled with hot, greasy, or moist food, it leads to complaints and unnecessary material waste. Practical packaging solutions must make transport safe while also suiting the respective sales process.

Plan costs, staff, and communication realistically

Reusable packaging creates additional work steps. Containers must be issued, collected, sorted, and, depending on the system, washed or collected. This is balanced by potential savings on single-use items and better recognition among regularly returning customers. There is no one-size-fits-all calculation: a café with many regular customers will assess reusable packaging differently than a snack bar at a train station with mostly walk-in customers.

Therefore, start with the most profitable affected items. These are often hot drink cups and one or two standard sizes for lunch dishes. Too many container formats increase inventory, training effort, and error rates. A small, clearly labeled reusable range is usually better in everyday business than a large selection that hardly anyone can use with confidence.

Communication should take place directly at the point of order. A short notice such as “Reusable cups available - deposit refunded upon return” is easier to understand than long explanations. If customers are allowed to bring their own containers, this information should also be clearly visible at the counter, entrance, or ordering terminal.

For employees, clarity is what matters most. They should know which products are issued in reusable packaging, when a deposit is charged, and how to handle dirty returns. A brief induction before starting and a clear cash register designation prevent arguments and speed up serving.

Those who plan reusable packaging as a permanent part of their to-go offer, rather than just offering it on the side, will be better able to manage the effort and costs. The right combination of reusable packaging for affected items and functional single-use packaging for other applications creates a process that remains reliable for both the business and its customers.

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