Packaging Act for Cafés & Foodservice: Key Legal Obligations

  • Since July 2022, all businesses distributing service packaging must register with LUCID.
  • Since 2023, the reusable offering obligation has applied to to-go drinks and meals in plastic packaging.
  • Certain single-use plastics, such as polystyrene cups, have been prohibited since 2021.

The Packaging Act (Verpackungsgesetz – VerpackG) regulates how packaging is placed on the market and disposed of in Germany. For hospitality and to-go businesses, it is especially relevant because they distribute service packaging daily – cups, bags, and boxes filled directly at the counter. This article provides an overview and does not constitute legal advice.

1. Registration in the LUCID Packaging Register

For service packaging, dual system licensing can be handled upstream by the supplier. However, registration with the Central Agency Packaging Register (Zentrale Stelle Verpackungsregister – LUCID) has been mandatory for all final distributors since 1 July 2022 – even if packaging is purchased pre-licensed. Registration is free of charge and completed online.

2. Reusable Packaging Offering Obligation (§ 33 VerpackG)

Since 1 January 2023, businesses selling takeaway drinks in single-use cups or food in single-use plastic packaging must also offer a reusable alternative. This reusable option must not be sold on worse terms or at a higher price than the single-use version.

  • Applies to all single-use beverage cups – regardless of material
  • Customers must be clearly informed of the reusable option via clearly visible signage
  • Exemption: businesses with a maximum of 5 employees and no more than 80 m² of retail space – though they are required to fill customer-owned containers on request

3. Ban on Certain Single-Use Plastics

Since 3 July 2021, single-use plastic cutlery, plates, and drinking straws, as well as cups and food containers made of expanded polystyrene (Styrofoam), may no longer be placed on the market in Germany. Paper cups remain permitted, but carry mandatory labelling under the Single-Use Plastics Labelling Ordinance (Einwegkunststoffkennzeichnungsverordnung) due to their coating.

4. Outlook: EU Packaging and Packaging Waste Regulation (PPWR)

The new EU Packaging and Packaging Waste Regulation (PPWR) has applied since August 2026, gradually introducing further requirements such as recyclability performance grades and reusable packaging quotas. Many provisions will take effect over the coming years – keeping abreast of developments is well advised.

Checklist for Your Business

  • LUCID registration in place?
  • Licensing of service packaging clarified (in-house or via supplier)?
  • Reusable alternative offered and prominently promoted?
  • No prohibited single-use plastics remaining in use?

Learn more – Paper cups, kraft bags, and more – we are happy to advise you.