Different industries share frustration at the lack of guidance. They are asking to stop the clock so a targeted revision for the legislation can be created. For operators, regardless of size, the implementation of compliant and scalable systems will require significant investments, reorganization of operations and training of staff in addition to substantial preparation time.
Reusable packaging systems will require structural changes to existing operations, each of which come with their own environmental considerations depending on the design and management of the system. By contrast, BYO packaging raises a different set of challenges regarding food safety and consumer health, as it risks introducing foreign contaminated objects into previously strictly controlled environments in restaurants.
Risk to food safety and the environment
In particular, the lack of guidance relating to Articles 32 and 33 is consequential, as it must be applied across a wide range of operators offering diverse products and menus.
In operational terms, the BYO obligation raises legitimate sanitary and liability concerns, as food service operations rely on controlled hygiene environments. Customer-provided containers can be outright dirty and contaminated, and restaurants cannot thoroughly assess or wash them on the premises. While the PPWR exempts operators from liability, it does not reduce the health risks for consumers, as BYO will lead to an increased risk of cross-contamination through pathogens and allergens.
Similarly, reusable packaging does not automatically deliver environmental benefits. It only works when return rates are high and logistics are well managed. The EU Joint Research Centre has shown that these conditions are hard to achieve in off‑premises settings. When these conditions fall short, reusable systems can end up with a higher life‑cycle footprint than fully recyclable paper options.