The 5% line in PPWR Annex V: why packaging teams need to act now

As currently drafted, a plastic strawberry tray below 1.5 kg is in principle caught by PPWR Annex V point 2, subject to the exemptions built into the Regulation and the further Commission clarification due by February 2027. A paper strawberry tray with a thin plastic barrier, provided the plastic content stays at or below 5% of total weight, is not covered by the same Annex V ban.

Same shelf. Same fruit. One threshold changes the outcome.

That 5% line is already shaping early material decisions across the European food and FMCG sector. It is also one of the most widely misread rules in Annex V. In portfolio reviews over the last six months, we have seen the same three misunderstandings repeat: teams treating the 5% threshold as a universal safe harbour, teams assuming the PPWR format bans replace the Single-Use Plastics Directive, and teams believing the 2030 date leaves plenty of time. None of those assumptions holds.

What the 5% line actually is

From 1 January 2030, PPWR Annex V restricts six packaging formats.

For Annex V points 1 to 4, the restrictions target specific single-use plastic packaging formats:

• grouped packaging designed to bundle products sold in bottles, cans, tins, pots, tubs, and packets;

• single-use plastic packaging for prepacked fresh fruit and vegetables below 1.5 kg;

• single-use plastic packaging for food and beverages filled and consumed within the HoReCa sector;

• single-use plastic packaging for individual portions of condiments, preserves, sauces, coffee creamer, sugar, and seasonings in the HoReCa sector.

Annex V point 5 covers single-use packaging for cosmetic, hygiene, and toiletry products used in the accommodation sector, regardless of material.

Annex V point 6 covers very lightweight plastic carrier bags.

For points 1 to 4, paper-based packaging with a plastic content of not more than 5% by weight is not covered by those format bans. That is the rule. It is a scope rule for Annex V. It determines whether those specific bans apply. It is not a blanket exemption from the rest of the PPWR.

Three consequences follow from that distinction.

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Four things the 5% line does not do

1. It does not remove SUPD exposure

The Single-Use Plastics Directive ((EU) 2019/904) continues to apply in parallel with the PPWR. It operates by product category, not by the Annex V 5% threshold.

That means a format can sit outside the PPWR Annex V ban and still fall within SUPD obligations. Where a format falls within a SUPD product category, requirements such as consumption reduction, extended producer responsibility costs, or, in the case of beverage cups, marking obligations can still apply.

A paper-based beverage cup or food container with a plastic barrier at 4.9% may therefore avoid an Annex V ban and still remain exposed under the SUPD.

2. It does not remove PPWR recyclability obligations

From 2030, packaging placed on the EU market must meet the PPWR recyclability requirements under Article 6.

A paper-based format that qualifies under the 5% rule must still pass the relevant recyclability assessment. A thin barrier may help avoid an Annex V ban, but it does not guarantee a compliant recyclability outcome. Repulpability, fibre yield, screening rejects, and the impact of coatings or dispersions on recycling performance still matter.

In other words: avoiding the format ban is not the same as being recyclable in practice.

3. It does not waive minimisation requirements

The 5% line does not remove PPWR minimisation duties either. Packaging must still be reduced to the minimum necessary weight and volume while maintaining function. A paper-based redesign that gets below the 5% threshold but adds unnecessary bulk, complexity, or non-functional elements creates a different compliance problem.

4. It does not automatically trigger recycled-content targets either

The opposite mistake is just as common.

PPWR Article 7 recycled-content targets apply to plastic packaging and to plastic parts within scope. A paper-based pack with a plastic fraction at or below 5% by weight does not automatically fall into the plastic recycled-content target logic in the same way as a plastic pack does.

That is relevant for planning, but it is not a free pass. Recyclability, minimisation, and any parallel SUPD exposure still remain on the table.

Why this matters for material strategy now

The PPWR applies from 12 August 2026. The Annex V format restrictions apply from 1 January 2030.

Three and a half years sounds comfortable. In practice it is not.

Reformulating a barrier structure from a conventional plastic tray into a paper-based format at or below the 5% threshold typically requires:

• new substrate qualification,

• coating selection and validation,

• filling-line compatibility testing,

• migration and shelf-life studies,

• supplier capacity booking,

• artwork and specification updates,

• and revised conformity documentation.

In our client work, we typically budget 18 to 30 months for a full reformulation at portfolio scale. That puts the decision window, not the execution window, firmly inside 2026 and 2027.

There is also a strategic fork.

Reformulating below the 5% line may keep a similar retail format on shelf, but it carries barrier-performance and recyclability risk.

Investing in reusable or refillable systems may remove the format from Annex V exposure entirely, but it requires a different commercial, operational, and logistical model.

Both can be valid. Neither is cheap.

What we recommend

Run a three-step Annex V exposure audit at portfolio level before the end of Q2 2026.

1. Map exposure

Identify every SKU whose format may fall within Annex V points 1 to 6. The most common hits are prepacked fruit and vegetable trays, HoReCa service packaging, condiment sachets, grouped packaging, and accommodation miniatures.

2. Classify the composition

For paper-based candidates, verify the plastic content against the 5% rule using current bill-of-materials data, not assumed specifications or supplier marketing claims.

3. Decide the route

For each in-scope SKU, choose deliberately between reformulation below 5%, format redesign for reuse, or portfolio rationalisation.

The brands that run this work in 2026 will still have time to reformulate, requalify, and restructure their supplier base.

The brands that discover their exposure in 2029 will be making emergency decisions under cost, capacity, and capex pressure.

Key takeaways

• PPWR Annex V restricts six packaging formats from 1 January 2030.

• For Annex V points 1 to 4, paper-based packaging with not more than 5% plastic is outside those specific format bans.

• The 5% threshold is a scope rule, not a universal safe harbour.

• SUPD exposure, recyclability requirements, and minimisation duties can still apply.

• Recycled-content targets for plastic packaging do not automatically apply to a paper-based format with a plastic fraction at or below 5%.

• The decision window is now. Execution timelines of 18 to 30 months mean 2026 is the realistic start point for any serious portfolio-wide response.