Packaging Waste Obligations for Food Businesses: CSRD, EPR and PPWR Compliance

If your small or growing business (SME) places packaged food or beverages on the EU market under your own brand, you are almost certainly required to register with at least one national Extended Producer Responsibility (EPR) scheme — even at very small volumes. From 12 August 2026, the new EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) layers a harmonised set of recyclability, recycled-content, and labelling requirements on top of those national schemes, and large retailers are increasingly using both EPR registration and CSRD-style sustainability disclosures as gating criteria for shelf placement.

This guide explains how a small food producer, beverage brand, contract packer, or private-label supplier handles packaging obligations under three overlapping frameworks: EPR (national, mandatory), PPWR (EU-wide, applies from August 2026), and CSRD/VSME (sustainability reporting). The goal is one consistent dataset that satisfies all three.

TL;DR

• EPR registration is mandatory in every EU country where you place packaged food on the market — even at small volumes, even for one brand. Penalties for non-registration include retailer delisting and direct fines.
• PPWR (Reg 2025/40) entered into force on 11 February 2025; generally applies from 12 August 2026. It harmonises packaging design, recyclability, recycled-content, and labelling requirements across the EU and replaces the previous Packaging Directive (PPWD).
• Most non-listed food SMEs are not in CSRD scope under the 2026 Omnibus (more than 1,000 employees and more than €450M turnover). Use VSME B7 (Resource use, circular economy and waste) and B4 (Pollution) for retailer questionnaires.
• EPR data feeds VSME directly. Same material categories, same units (kg by material), same period — reuse the EPR submission as the basis for the VSME disclosure.
• Eco-modulated EPR fees are now common — non-recyclable formats cost more per kg than recyclable ones. PPWR will tighten this further from 2030.

Why Packaging Waste Matters Under CSRD, EPR, and PPWR

Food packaging is highly visible, highly regulated, and closely linked to environmental impacts including waste, litter, and pollution. Three frameworks now overlap on the topic:

Under EPR (national)

• Producers are legally responsible for packaging placed on the market
• Registration, periodic reporting, and per-kg fees apply at national level
• Schemes are eco-modulated: non-recyclable materials cost more
• Retailers increasingly require proof of compliance (registration numbers, scheme membership)

Under PPWR (EU-wide, from 12 August 2026)

• Harmonises packaging design, recyclability, recycled-content, and labelling rules
• Sets reduction and reuse targets staged through 2030, 2035, and 2040
• Restricts certain single-use packaging formats
• Requires recycled-content thresholds for plastic packaging from 2030 (10–35% depending on format)

Under CSRD (post-Omnibus, in-scope reporters only)

• ESRS E5 (Resource use and circular economy) requires disclosure of how resources are used and waste prevented
• Packaging design and recyclability are treated as material circular-economy topics
• Packaging data feeds the buyer’s Scope 3 calculations

For a small food business, the practical answer is one consistent dataset that satisfies all three — built from invoices and EPR submissions you already produce.

For broader circular reporting context, see the resource use & circular economy topic hub.

Who Is Responsible Under EPR?

In most EU countries, the producer is the entity that:

• Places packaged food on the market under its own brand, or
• Imports packaged food into a country

This typically captures:

• Small food brands (own-brand sauces, snacks, baked goods)
• Beverage producers
• Contract manufacturers selling under their own label
• Distributors first placing imported packaged food on the market

Even very small volumes can trigger EPR registration in some Member States. Operating in multiple EU countries usually requires multiple national registrations.

What Packaging Is Covered?

Materials commonly tracked:

• Plastics (split by polymer where required: PET, HDPE, PP, etc.)
• Paper and cardboard
• Glass
• Metal (steel, aluminium)
• Composite or multilayer materials
• Bio-based or compostable materials (treated separately under most EPR schemes)

Clear material breakdowns by weight are essential for both EPR and CSRD/VSME.

How to Manage Packaging Obligations — Step by Step

Step 1: Inventory all packaging placed on the market

For each finished product, record:

• Product SKU
• Each packaging element (primary, secondary, tertiary)
• Material per element (PET, paperboard, aluminium, etc.)
• Weight per element in grams
• Annual units sold per country

The output is a packaging master register — typically a spreadsheet or simple database — that becomes the source of truth for both EPR submissions and the VSME disclosure.

Step 2: Confirm EPR registration in every relevant country

Each EU country runs its own EPR scheme(s). Examples:

• France — CITEO (general packaging), Adelphe (beverage)
• Germany — LUCID register + a take-back system contract (e.g. Der Grüne Punkt, Interseroh, Reclay)
• Italy — CONAI
• Spain — Ecoembes (plastic, metal, paper, cartonboard) + Ecovidrio (glass)
• Netherlands — Verpact (formerly Afvalfonds Verpakkingen)
• Belgium — Fost Plus + IVCIE registration

Keep a register of:

• Countries where you place packaging
• Scheme names
• Registration numbers
• Renewal dates and reporting deadlines

Step 3: Submit periodic EPR reports

Most schemes require quarterly or annual reporting of packaging volumes by material, with eco-modulated fees calculated against the figures. Save:

• Submitted volumes (kg by material)
• Fees paid
• Acknowledgement / receipt from the scheme

These records become evidence for retailer audits and the basis of the VSME B7 disclosure.

Step 4: Map EPR data to VSME B7 (and B4 where pollution is material)

EPR data and VSME B7 use compatible structures. Reuse:

• Same material categories (plastic, paper, glass, metal, composite, bio-based)
• Same units (kg per year)
• Same reporting period

A simple VSME B7 disclosure table for a food business:

If pollution is material to your business — for example, fertiliser run-off in agriculture, or releases from food-processing operations — also disclose under VSME B4 (Pollution of air, water and soil).

Step 5: Set reduction and design targets aligned with PPWR

Under VSME (and increasingly, retailer expectations), set targets that reflect PPWR’s direction of travel:

• Quantitative targets: % reduction in plastic weight, % shift to recyclable mono-materials, % recycled-content increase
• Qualitative targets: phase-out of non-recyclable formats, switch to refillable formats where viable

PPWR alignment markers worth referencing:

• Recycled content in plastic packaging: 10–35% from 2030, depending on format
• All packaging recyclable by 2030 (with formal “design for recycling” rules)
• Empty space ratios capped (~50% for grouped/transport packaging)
• Reuse targets staged from 2030 in beverage and transport packaging

Targets do not need to be ambitious to be valid; they need to be clearly defined and monitored.

Documentation Retailers Commonly Request

Large retailers (Carrefour, Tesco, REWE, Albert Heijn, Lidl, etc.) act as compliance gatekeepers. Typical asks from a food SME supplier:

• EPR registration numbers (per country where the retailer operates)
• Packaging master register (material × weight per SKU)
• Recyclability claims with supporting design-for-recycling evidence
• Recycled-content percentages by material
• Short sustainability or packaging statement (often less than 2 pages)

This documentation overlaps almost completely with VSME B7 — supplying retailers with one VSME-aligned packaging document satisfies most of these asks.

Reporting Under CSRD vs VSME

Under the 2026 Omnibus revision, CSRD applies directly only to undertakings with more than 1,000 employees and more than €450M turnover. Almost every food and beverage SME falls below the threshold and uses VSME for retailer questionnaires. The Omnibus value-chain cap also prevents in-scope clients from demanding more from sub-1,000-employee suppliers than VSME requires.

EPR and PPWR, however, apply regardless of CSRD scope — EPR registration and PPWR compliance are mandatory for any producer placing packaging on the EU market.

Frequently Asked Questions

Do small food businesses really need to register for EPR?

Yes. In most EU countries, even small volumes of packaging trigger EPR obligations once you place packaged food on the market under your brand. Failure to register can lead to retailer delisting, fines, and back-payment of fees. Operating in multiple EU countries usually requires multiple national registrations.

Is EPR compliance enough for CSRD or retailer packaging reporting?

No. EPR focuses on legal responsibility and per-kg fees; CSRD (and the VSME B7 disclosure that fashion/food/retail SMEs use) focuses on transparency, circularity, and strategy. EPR data is a strong foundation for the disclosure — same material categories, same reporting periods — but the VSME narrative adds context (targets, design choices, reduction initiatives) that EPR alone does not provide.

Do compostable or bio-based packages remove EPR obligations?

Usually not. Most EPR schemes still require registration and reporting for compostable or bio-based packaging, often under a dedicated category. Recyclability or compostability claims must be carefully documented and aligned with the EN 13432 standard (industrial composting) or the appropriate national scheme — unsupported claims can trigger greenwashing scrutiny.

What changes under PPWR from 12 August 2026?

PPWR (Regulation (EU) 2025/40) replaces the previous Packaging Directive (PPWD). It harmonises packaging design rules across the EU, sets recycled-content targets for plastic packaging from 2030, and introduces reuse and reduction targets staged through 2030, 2035, and 2040. From August 2026, packaging placed on the EU market must meet PPWR design-for-recycling, labelling, and (in some categories) recycled-content thresholds. Eco-modulated EPR fees will tighten in line.

How do I avoid double work between EPR and VSME?

Use the same packaging master register for both. Same SKUs, same materials, same weights, same reporting period (typically calendar year). The EPR submission is the legal artefact; the VSME disclosure is the same data presented with circular-economy context, targets, and a brief narrative.

Can a small food business manage this without consultants?

Yes. Most small food businesses manage packaging compliance using a spreadsheet master register, scheme-portal submissions, and supplier invoices. Structure and consistency matter more than tooling complexity. Investment in better tools makes sense once you operate across more than 3–4 EU countries or place more than ~10 SKUs on the market.

Key Terms

• CSRD – Corporate Sustainability Reporting Directive (Directive (EU) 2022/2464); revised by Omnibus I in March 2026.
• VSME – Voluntary Sustainability Reporting Standard for SMEs (Basic B1–B11; Comprehensive C1–C9). Adopted as a Commission recommendation on 30 July 2025.
• B7 Resource use, circular economy and waste management – VSME disclosure covering material flows, recyclability, and circular practices.
• B4 Pollution of air, water and soil – VSME disclosure relevant to processing and farming-stage pollution.
• EPR (Extended Producer Responsibility) – National schemes requiring producers to register, report packaging volumes, and pay per-kg fees.
• PPWR (Packaging and Packaging Waste Regulation) – Regulation (EU) 2025/40; in force 11 February 2025, generally applies from 12 August 2026; replaces the previous Packaging Directive.
• Eco-modulation – EPR fee adjustments based on packaging design (recyclable formats pay less; non-recyclable formats pay more).
• Recyclable – Designed and collected for recycling at scale; PPWR introduces formal design-for-recycling rules from 2030.
• Recycled content – Share of post-consumer recycled material in new packaging; PPWR sets minimum thresholds for plastic packaging from 2030.
• Circular economy – Designing out waste and keeping materials in use through reuse, repair, and recycling.
• ESRS E5 – CSRD topical standard on resource use and circular economy.