Bread bags, cake boxes, coffee cups, pastry boxes, or carrier bags: packaging is part of the daily business of bakeries and confectioneries. Since August 12, 2026, the first mandatory requirements of the new EU Packaging Regulation (PPWR) have been in effect. This introduces new substance limits, conformity assessments, and labeling obligations for businesses. Particularly important for craft businesses: which obligations actually apply depends largely on the legal role a company plays with regard to the respective packaging.

The Packaging and Packaging Waste Regulation (PPWR ) establishes, for the first time, directly applicable and largely uniform EU rules for packaging and packaging waste. The regulation has been in force since February 2025, and the first key provisions have been applied since August 12, 2026.

For bakeries and confectioneries, however, this doesn't mean that all packaging has to be replaced overnight. The PPWR will be implemented gradually. Some requirements are already in place, while many more will follow in the coming years.

The most important task at present is therefore to record the packaging used and to clarify one's own legal role. The Austrian Federal Economic Chamber identifies precisely this classification as a key challenge of the new regulation.

From cake boxes to coffee-to-go cups

The PPWR defines the term "packaging" very broadly. Basically, it covers packaging placed on the EU market, regardless of whether it is empty or already filled, what material it is made of, or whether it was produced in the EU or in a third country.

For bakeries and confectioneries, the regulation could therefore affect a large part of the packaging used every day: bread and pastry bags, cake boxes, chocolate boxes, carrier bags, coffee cups, takeaway containers, films, shipping boxes, lids, closures or labels.

PPWR distinguishes between different types of packaging. Sales packaging, together with the product, forms a sales unit. Service packaging is filled directly at the point of sale. Transport packaging protects products during delivery and handling.

A separate subcategory is takeaway packaging. This includes service packaging that is filled with beverages or prepared food at a staffed sales outlet and then consumed at another location without further preparation.

This means that coffee-to-go, snacks, breakfast offers and other takeaway products are now receiving greater attention from European packaging policy.

The most important question: What role does the company itself play?

One of the biggest innovations of the PPWR lies not in the material, but in the distribution of responsibility.

The regulation distinguishes, among other things, between producers, importers, distributors, suppliers, and manufacturers. Different obligations apply depending on this role.

In principle, a producer is defined as anyone who manufactures, develops, or has manufactured packaging or a packaged product under their own name or brand.

This definition is particularly relevant for craft businesses. A bakery that buys and uses standardized packaging from a supplier may be classified differently under the law than a company that has individually designed packaging produced under its own name.

The question of whether a finished package is purchased or assembled from several components at the factory can also be crucial.

PFAS limits apply to food packaging

Since August 12th, the first concrete material requirements have been in effect. These include a total limit of 100 milligrams per kilogram for lead, cadmium, mercury and hexavalent chromium.

Also particularly relevant for the food industry are the new limits for per- and polyfluoroalkyl substances, or PFAS for short, in food contact packaging.

The PPWR specifies several limit values. For specifically analyzed PFAS excluding polymeric PFAS, the limit is 25 ppb, and for their sum, 250 ppb. For PFAS including polymeric PFAS, the limit is 50 ppm.

Especially with packaging that comes into direct contact with food, bakeries and confectioneries should therefore clarify with their packaging suppliers whether the materials used meet the new requirements and what technical evidence is available.

Packaging suppliers are becoming important partners

Suppliers of packaging and packaging materials also face clearly defined obligations under the PPWR. They must provide the manufacturer with the information and documentation needed to demonstrate the conformity of packaging.

It is important to distinguish between two things: The supplier must provide technical information. This does not automatically mean that they owe the customer a completed EU declaration of conformity for their specific packaging.

It is therefore worthwhile for businesses to actively utilize existing supplier relationships now. For frequently used bread bags, pastry packaging, cake boxes, coffee cups, or individually printed packaging, it should be clarified what technical documentation is available and who within the supply chain is responsible for compliance.

The manufacturer must document compliance.

Producers are generally only allowed to place packaging on the market that complies with the applicable requirements of the PPWR.

You must carry out a conformity assessment procedure and document the results technically. The procedure for this is set out in Annex VII of the PPWR .

If the assessment shows that the packaging complies with the applicable requirements, the manufacturer issues an EU declaration of conformity. The structure of this declaration is set out in Annex VIII of the Regulation .

For small craft businesses, it is therefore crucial not to assume prematurely that they have to create such a declaration for every type of packaging used. First, their own role according to the PPWR (Products Packaging and Materials Review) must be correctly determined.

New information on packaging

Producers have also been subject to identification and labeling requirements since August 12th.

Packaging must generally bear a type, batch, or serial number, or some other means of identification. If this is not possible due to the size or nature of the packaging, the relevant information can be found in the accompanying documentation.

Furthermore, the producer must provide his name, postal address and, if applicable, electronic communication options.

This can be done via QR code or other data carrier. Direct printing or a label are also possible. If none of these options are practical, the information can be provided via accompanying documents.

Small bakeries and confectioneries will receive relief.

The small business regulation is of great importance, especially for the Austrian baking and confectionery trade.

According to the PPWR, micro-enterprises are defined as companies with fewer than ten employees and less than two million euros in revenue or balance sheet total.

There are exemptions and exceptions for such businesses. However, they are not completely exempt from the PPWR (Product and Distribution Regulations). According to the Austrian Federal Economic Chamber (WKO), micro-enterprises are subject to at least the obligations of a distributor in many situations.

The Chamber of Commerce therefore recommends informing the respective supplier that your company is a micro-enterprise. This clarifies within the supply chain who assumes the role of producer and the associated obligations.

Private label alone does not automatically make one a producer.

For many bakeries and confectioneries, the handling of individually designed packaging is particularly interesting.

If a micro-enterprise buys ready-made packaging within the EU and has it labelled with its own name or brand, the micro-enterprise regulation generally applies, according to the current assessment of the Chamber of Commerce.

Even if a finished, initially neutral package is subsequently branded with a company logo or label, this branding alone does not automatically make the micro-enterprise a producer, according to the interpretation presented by the Austrian Federal Economic Chamber (WKO).

For small businesses with their own cake boxes, paper bags, gift packaging or other branded packaging, this is a crucial distinction.

Multi-part packaging can become a problem

The situation may be different if the finished sales packaging is only produced in-house.

The Austrian Federal Economic Chamber (WKO) explicitly mentions the case where individual packaging components are purchased and then assembled during filling. Examples given include containers, lids and sealing rings, or bags, clips, ribbons and brand labels.

If the final sales unit is only created through assembly or filling within the company, the small business regulation does not apply according to the current interpretation of the Austrian Federal Economic Chamber (WKO). The company can therefore become the original producer of the sales packaging itself.

This question should therefore be examined more closely, especially for businesses with elaborately assembled gift, chocolate, seasonal or specialty packaging.

Distributors cannot ignore the PPWR either.

Bakeries or confectioneries that are merely considered distributors of a particular type of packaging are nevertheless not completely exempt from responsibility.

Distributors must take due care to comply with the PPWR requirements and, in particular, ensure that producers or importers have complied with their identification and labelling obligations.

In practice, this also makes it more important for smaller companies to be able to trace where packaging comes from and who within the supply chain is responsible for its compliance.

What happens to existing packaging stocks?

There is an important transitional rule for inventory levels.

Packaging that was lawfully placed on the market before August 12, 2026, is generally exempt from the newly applicable obligations. The Austrian Federal Economic Chamber (WKO) explicitly cites existing stocks held by distributors as an example.

However, the crucial factor is the legal concept of "placing on the market." Not every box or bag that was in a company's warehouse on August 11th was automatically considered legally placed on the market before the cut-off date.

For larger inventories or cases of doubt, a thorough examination of the specific delivery and distribution situation is therefore recommended.

Austria has not yet finalized its accompanying regulations.

In addition to the European regulations, there is currently an additional uncertainty in Austria.

The Chamber of Commerce points out that essential national implementing regulations for the PPWR are still lacking. Adjustments are particularly necessary to the Waste Management Act 2002, extended producer responsibility, collection and recycling systems, and penalty provisions.

According to the information available to the Austrian Federal Economic Chamber (WKO) on August 10, 2026, a concrete draft assessment was not yet available.

This means that there are currently some differences between the existing Austrian definitions and the new distribution of roles under the PPWR. Until corresponding national regulations are adopted, existing rules must be interpreted in conformity with EU law.

The responsible Federal Ministry has published an information sheet on the application of the Packaging Ordinance in connection with the PPWR .

What companies should specifically check now

For bakeries and confectioneries, a structured inventory is currently more sensible than a hectic replacement of all packaging.

The first step should be to identify which packaging is actually used in the company. This includes not only classic product packaging, but also carrier bags, takeaway packaging, coffee cups, shipping boxes, gift wrapping, films and labels.

The second step is to clarify what role the company itself plays in the respective packaging. Companies should pay particular attention to individually produced private-label packaging and packaging that is assembled from several components on-site.

After that, it's worth contacting the packaging supplier directly. Companies should clarify which technical documents are available and whether the requirements in effect since August 12th, in particular the substance limits for food contact packaging, are met.

Existing stock levels should also be documented in order to track which packaging was already placed on the market before the cut-off date.

August 12th is just the beginning.

The currently applicable regulations are only the first stage of a much larger transformation. Further requirements of the PPWR will gradually come into effect in the coming years.

This includes, among other things, further requirements regarding recyclability, packaging minimization, labeling and reuse.

For bakeries and confectioneries, packaging is increasingly becoming a strategic business issue. Packaging must protect food, function practically, and match the company's image. In the future, it will also be necessary to verify whether it meets European environmental and chemical requirements and who is responsible for providing this proof.

Smaller craft businesses, in particular, don't need to become packaging law experts themselves. However, they should know what packaging they use, their legal role in it, and what documentation their suppliers can provide. Because with the PPWR (Packaging Products Regulation), the everyday bread bag, cake box, or to-go coffee cup has definitively become a compliance issue.