# Fast food has bet on fibre, while France and the PPWR are writing reuse into dine-in service

> McDonald's built its European packaging on fibre, which was 96% of primary guest packaging in Europe at the end of 2024, but France has required reusable tableware for meals eaten on site since 1 January 2023, the EU's packaging regulation bans single-use plastic packaging for food and drink consumed on HORECA premises from 1 January 2030, and takeaway outlets must offer reuse and accept customers' own containers.

Publisher: Strategic Packaging Insights  
Published: 2026-10-26  
Last updated: 2026-10-26  
Page: https://www.strategicpackaginginsights.com/insights/quick-service-restaurant-packaging-mcdonalds-reuse-rules/

**McDonald's built its European packaging on fibre, which was 96% of primary guest packaging in Europe at the end of 2024, but France has required reusable tableware for meals eaten on site since 1 January 2023, the EU's packaging regulation bans single-use plastic packaging for food and drink consumed on HORECA premises from 1 January 2030, and takeaway outlets must offer reuse and accept customers' own containers.**

Quick-service restaurants sit where three kinds of packaging rule meet: format bans, reuse offers and consumption cuts for cups and food containers. This piece sets McDonald's own published goals and its October 2025 reuse study against those rules in France, the EU and three US states, using the SPI Regulation Tracker's 79 rules and the SPI Packaging Buyers Database.

## Executive summary

Quick-service restaurants buy a narrow set of packaging, cups, lids, clamshells, wraps, cartons and bags, in very large numbers, and most of it is used for minutes. That makes the sector a direct target of rules that other industries meet only at the edges. McDonald's, with 45,356 restaurants at the end of 2025 (Restaurants by Market 2025), is the clearest case because it publishes goals, progress and, unusually, a full study of what reuse did in its own European restaurants.

The company's strategy is fibre plus recycling. At the end of 2024, 96% of its primary guest packaging in Europe was fibre-based, according to its October 2025 reuse report, while 98.99% of fibre-based guest packaging globally came from recycled or certified sources, and it was 90.93% of the way to sourcing all primary guest packaging from renewable, recycled or certified materials by the end of 2025 (McDonald's Goal Performance and Reporting). SPI has not yet confirmed an end-2025 result.

The rules are moving towards reuse. France has required reusable tableware for meals served on site since 1 January 2023 in outlets able to serve at least 20 covers at once (economie.gouv.fr, 17 December 2025). From 1 January 2030, Annex V point 3 of Regulation (EU) 2025/40, the PPWR, bans single-use plastic packaging for food and drink filled and consumed on HORECA premises (Commission Notice C/2026/3084). For takeaway, the PPWR requires outlets to accept customers' own containers and to offer reusable packaging, with an indicative target of 10% by 2030 under Article 33(5).

McDonald's modelled that 2030 takeaway case with PwC UK and reported greenhouse gas emissions up 61% and plastic packaging waste up 626% per restaurant per year (October 2025). Its France dine-in model came out closer to neutral on emissions, at +9% including initial stock, with fibre waste down 94%. The difference is the number of uses: 33.9 on average in French dine-in service against 1.5 to 2.6 for takeaway cups.

For leaders, the lesson is to plan dine-in and takeaway separately. Dine-in reuse works where items come back many times, and the 2030 EU rule will make it the default. Takeaway reuse is an offer and an indicative target, where uptake, returns and washing set the result. Map every pack by channel and plastic share before the Annex V guidelines due on 12 February 2027.

## Key findings

1. McDonald's had 1,630 restaurants in France, 1,382 in Germany, 805 in Italy, 665 in Spain, 618 in Poland and 266 in the Netherlands at 31 December 2025, and says the PPWR affects more than 6,900 of its restaurants in the EU and EEA (Restaurants by Market 2025; October 2025 report).
2. At the end of 2024 McDonald's was 90.93% of the way to its goal of 100% renewable, recycled or certified primary guest packaging by the end of 2025, and 99.82% of guest packaging items had no intentionally added fluorinated compounds (Goal Performance and Reporting).
3. France has required reusable tableware for dine-in meals since 1 January 2023 in outlets that can serve at least 20 covers at once, naming fast food among the outlets covered (economie.gouv.fr, 17 December 2025).
4. From 1 January 2030 the PPWR bans single-use plastic packaging for food and drink filled and consumed on HORECA premises, and the Commission reads the Annex V points 1 to 4 bans as covering paper-based packaging with more than 5% plastic (Commission Notice C/2026/3084, sections 16 and 17).
5. In McDonald's own model, French-style dine-in reuse averaged 33.9 uses and cut fibre waste 94%, while the 2030 takeaway case assumed 2.6 uses and raised emissions 61% (October 2025 report).
6. **SPI calculation:**  the 2030 takeaway case would need about 6.9 times more uses per item (18 against 2.6) to break even on emissions, and reported takeaway uptake of 4% in the Netherlands is 2.5 times short of the 10% indicative target.
7. In the US, California has restricted producers from selling or distributing EPS food service ware since 1 January 2025 because the 25% recycling rate was not met (CalRecycle), and Washington and Oregon ban EPS foodware under their own laws ([PR-US-012](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-012/), [PR-US-013](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-013/)).

## What a quick-service restaurant actually buys

A quick-service packaging range is small in items and large in units. McDonald's lists paper-based straws, McFlurry cups without plastic lids, salad boxes and cutlery made from renewable fibre among its changes, and says it is developing moulded fibre to replace plastic lids and sundae cups (McDonald's Packaging, Toys and Waste page, consulted 25 October 2026). It prioritises recycled material for paper bags, napkins and cup carriers, and, depending on location, uses recycled material in some hot cups, cup sleeves, cartons, fry boxes, plastic beverage and dessert cups and some plastic lids.

The company's goals were set for the end of 2025 (Exhibit 2). Progress was published to the end of 2024 on its Goal Performance and Reporting page and in the Purpose and Impact Report 2024 to 2025, which covers calendar 2024. SPI found no published end-2025 figure on either page on 25 October 2026.

McDonald's names the hard items itself. Its reporting page says it struggles to find commercially scalable sources for some items, including linings and lids for hot items in fibre packaging, and that this affects the 2025 target. The Purpose and Impact Report puts it plainly: the company continues "to face challenges in identifying commercially scalable renewable, recycled or certified sources" (Purpose and Impact Report 2024 to 2025). Linings and lids are also where the plastic sits in a fibre pack, which matters for the EU's 5% test described below.

SPI analysis

The gap to the materials goal at the end of 2024 was 9.07 percentage points, and the fluorinated compounds gap 0.18 points. Those are small numbers on a global base, but they concentrate in the same components, linings, lids and coatings, that decide whether a fibre item counts as single-use plastic under the PPWR.

## The fibre rulebook behind the numbers

McDonald's defines its sourcing terms on its packaging page (Exhibit 3). Certified fibre means compliance with FSC, PEFC or SFI chain-of-custody or forest management requirements, and the finished product's certified content must be at least 70%. Wood fibre from seven named countries must carry FSC certification or FSC Controlled Wood status with full chain of custody.

These definitions explain how the company can be close to its materials goal and still face a plastic question. A board cup with a polyethylene lining can be certified fibre under McDonald's own test and still be single-use plastic packaging for an EU ban if plastic is more than 5% of its mass (Commission Notice C/2026/3084, section 17). The two tests answer different questions: where the fibre came from, and how much plastic the finished unit holds.

Recycling is the second half of the model. McDonald's reports that in Poland a recycler's technology allows 95% of food-contaminated fibre packaging, including polyethylene-lined cups, to be recycled, and that the Cup Collective, of which it is a founding partner, has launched paper cup collection in Brussels, Dublin and across the Netherlands (Packaging, Toys and Waste page). Its reuse study assumes a cautious 46% fibre recycling rate for dine-in and 3% for takeaway, against an estimated rate of around 92% in Germany (October 2025 report).

## A grid for quick-service packaging rules

SPI sorts the rules that reach a quick-service restaurant on two axes: the service channel (eaten on site, or taken away and delivered) and the type of instrument (a format ban, or an offer, target or fee). Each cell has a different compliance owner and a different lever (Exhibit 4).

The grid shows why fibre and reuse are not simple alternatives. A fibre clamshell clears every takeaway format ban in Exhibit 4, but the dine-in ban in France already reaches it, because the French rule is about single-use tableware of any material. The PPWR's dine-in ban, by contrast, is about single-use plastic packaging, so a fibre item with no more than 5% plastic stays outside it (Commission Notice C/2026/3084, section 17).

SPI analysis

For a fibre-led chain, the top-left cell is the one that moves from a French issue to an EU issue in 2030, and the bottom-right cell is the one that grows quietly through fees and national cup measures. The takeaway offer cell is the one McDonald's has argued against most directly.

## France: dine-in reuse since 2023

France reached the dine-in table first. The ministry's business guidance says that since 1 January 2023, restaurants may no longer use disposable tableware for meals served on site and must use reusable tableware, in establishments able to serve at least 20 covers simultaneously, citing fast food, workplace catering and school canteens (economie.gouv.fr, 17 December 2025). The ministry's environment portal describes the same rule as applying to outlets serving "plus de 20 couverts en même temps", more than 20 covers at once (notre-environnement.gouv.fr), so the exact threshold wording should be read in the legal text.

The guidance places the bans in article L. 541-15-10 of the Code de l'environnement, with product definitions in article D. 541-330 (economie.gouv.fr). SPI has not yet confirmed the article text or its penalty provisions on Légifrance. The rule sits in a longer list of dated AGEC bans that touch quick-service menus (Exhibit 5).

Three French rules bite on a burger chain beyond the dine-in switch. The toy ban removed free plastic toys from children's menus in 2022, the cup rule has limited partly plastic cups to traces of plastic since 1 January 2026, and the ban list includes "les boîtes en polystyrène expansé pour la nourriture à emporter ou à consommer sur le lieu de vente" (economie.gouv.fr; [PR-FR-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/france/pr-fr-002/)). Collective catering that sells takeaway must offer a reusable container or one made of recyclable materials, according to the same guidance; SPI has not yet confirmed whether that duty extends to commercial fast food.

France also counts reuse at national level. The 3R decree aimed for a 20% cut in single-use plastic packaging by the end of 2025, at least half through reuse, and the reuse thresholds rise from 5% in 2023 to 10% in 2027; the June 2025 interim review put reuse at 2.2% in 2023 ([PR-FR-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/france/pr-fr-001/), citing the ministry). Packaging carries Triman and Info-tri sorting marks under [PR-FR-003](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/france/pr-fr-003/), which takeaway bags and cartons must show.

In practice: McDonald's France.

McDonald's runs reusable items for dine-in beverages, desserts, fries and McNuggets in France, and fibre wraps for all sandwiches (Purpose and Impact Report 2024 to 2025). In its October 2025 study this is Scenario A: reusables mandatory for dine-in, with fibre wraps for sandwiches and burgers, at an average of 33.9 uses per item. Per restaurant per year, it reported plastic waste up 164%, fibre waste down 94%, greenhouse gas emissions up 9% including initial stock, and water use down 39%. France had 84% of its 1,630 restaurants franchised at the end of 2025 (Restaurants by Market 2025), so the switch runs through franchisee kitchens and dishwashers. The [France AGEC piece](https://www.strategicpackaginginsights.com/insights/france-agec-triman-packaging/) covers the wider French rulebook.

## The EU: what the PPWR says for HORECA, and where each point comes from

Regulation (EU) 2025/40 has applied since 12 August 2026 ([PR-EU-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-001/)). Its articles are long and the EUR-Lex HTML of the Regulation is published in parts, so SPI reads the HORECA provisions through three official channels: the Commission's guidance document, Commission Notice C/2026/3084 of 10 June 2026; the European Parliament's Legislative Observatory summary and press release; and the Commission's own pages. Exhibit 6 labels each point with its source.

**Dine-in.**  Article 25(1) provides that from 1 January 2030 economic operators shall not place on the market packaging in the formats and for the uses listed in Annex V, and point 3 lists single-use plastic packaging for food and beverages filled and consumed within HORECA premises, "which include all eating areas inside and outside a place of business, covered with tables and stools, standing areas" (Commission Notice C/2026/3084, section 16). The same section quotes the exemption for establishments without access to drinking water.

**The plastic test.**  Section 17 of the Notice says the bans in Annex V points 1 to 4 "do not cover only items that are made of 100 % plastic material", and that packaging containing not more than 5% plastic is not covered. The same section also refers to paper-based packaging "containing 5 % or more plastic" as covered, so an item at exactly 5% sits on a line the guidance words two ways; SPI reads the threshold as more than 5%, in line with the tracker rule note ([PR-EU-008](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-008/)).

**Takeaway.**  The Legislative Observatory summary says consumers should always be able to buy takeaway food and beverages in reusable or own containers, "on terms no less favourable than those applying to food and beverages offered in single-use packaging", and that take-away businesses will have to let customers bring their own containers at no additional charge (EP Legislative Observatory). The Commission's facts page adds that for takeaway and delivery, consumers will be able to choose single-use or reusable containers for the same price or less (DG ENV). Section 27 of the Notice names the 10% indicative 2030 target for take-away packaging in Article 33(5), and the Commission's competent authority list shows Ireland naming its local authorities for the obligations in Articles 32 and 33 (Green Forum).

Quick-service outlets meet two further PPWR rules that are already in force or fixed. Food-contact packaging has been subject to EU PFAS limits since 12 August 2026 ([PR-EU-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-002/)), the date from which McDonald's 99.82% figure matters as a compliance question, not only a goal. And beverage reuse targets for final distributors from 2030 reach HORECA bars and restaurants "in most cases", according to section 22 of the Notice ([PR-EU-006](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-006/)).

SPI analysis

The PPWR does not ban fibre packaging for dine-in. It bans single-use plastic packaging there, with a 5% line, while France bans single-use tableware of any material. A chain that has met France's rule with reusables already meets the PPWR's dine-in rule in France; a chain that relies on low-plastic fibre elsewhere may meet the PPWR without reuse, but only item by item. The [PPWR 2030 format restrictions piece](https://www.strategicpackaginginsights.com/insights/ppwr-2030-format-restrictions/) covers the other five Annex V entries.

## The Single-Use Plastics Directive: cups and food containers

Directive (EU) 2019/904 already shapes quick-service packaging, and the PPWR leaves its cup and container measures in place. Article 5 required Member States to prohibit expanded polystyrene food containers, beverage containers and cups, alongside cutlery, plates, straws and stirrers, from 3 July 2021 (EUR-Lex; [PR-EU-014](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-014/)). Article 4(1) requires measures to achieve "an ambitious and sustained reduction in the consumption" of the Part A products, which include cups for beverages with their covers and lids and food containers for immediate consumption, "either on-the-spot or take-away" (Exhibit 7).

The Notice spells out how the two laws divide the field. For packaging outside Annex V, Article 4 of the Directive still requires Member States to reduce consumption of beverage cups and rigid food containers, and "Such national consumption reduction measures can remain in place even after 1 January 2030" (Commission Notice C/2026/3084, section 16). A takeaway cup can therefore face a national cup charge under the Directive and a reuse offer under the PPWR at the same counter.

The Directive's tests on plastic are stricter than a casual reading suggests. The Commission's 2021 guidelines count plastic coatings and linings on paper or board, so a plastic-lined paper cup is a single-use plastic product for Articles 4, 7 and 8, whatever its plastic share ([PR-EU-014](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-014/), citing OJ C 216 of 7 June 2021). That is a different line from the PPWR's 5% test, and it is why cup marking and cup EPR apply to lined fibre cups.

Germany shows the fee side of the bottom-right cell. Its single-use plastics fund charges producers of items the Directive does not ban, such as to-go containers and cups, a levy paid to the Umweltbundesamt ([PR-DE-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/germany/pr-de-002/)). McDonald's Germany runs reusable cups with reusable lids for drinks, McFlurry and sundae, for dine-in and takeaway, with a EUR 2 deposit (Purpose and Impact Report 2024 to 2025).

## What McDonald's learned from reuse in three markets

McDonald's October 2025 report, The Complex Reality of Reusable Packaging in Europe, is the most detailed company data SPI holds on quick-service reuse. The company commissioned PwC UK to analyse four scenarios against a mainly fibre single-use baseline, using operational data from January to June 2024, and it operates in 30 European countries with more than 8,000 restaurants at the end of 2024 (Exhibit 8).

Uptake in the optional models was low. Reusables were 4% of takeaway items in Scenario B and under 1% in Scenario C, despite deposits, according to the report. The company draws its own conclusion: "Incentives, such as deposits, may not drive adequate returns" is a sentence from the report, and SPI quotes it here as McDonald's position, not as an independent finding.

The modelled results per restaurant per year are set out in Exhibit 9. Every figure is a change against the same restaurant's single-use baseline, so the rows can be read across.

Two patterns stand out. Dine-in reuse cut fibre waste in every scenario where it was reported, by 34% to 94%, and cut water use in A and B, because the comparison includes the washing of reusables against the making of fibre items. Plastic packaging waste rose in every scenario, from 14% to 1,031%, because a fibre baseline carries little plastic and reusables are made of plastic.

McDonald's packaging page sets out why the reusables are plastic: "Ceramics, metals, glass, and non-food-safe plastics were rejected due to safety concerns", together with the impracticality of serving millions of customers with heavier, brittle materials, and it says it has developed a plastic reusable packaging portfolio in response to reuse requirements (Packaging, Toys and Waste page). The report adds space and labour: sturdy reusables need more storage than compact fibre packs, crew must collect, sort and clean them, and just under a third of its European restaurants are in regions of extremely high or high water stress.

## Breakeven uses: the number that decides reuse

The report gives the number of uses each reusable item needs before it beats single-use on each measure (Exhibit 10). For Scenario 2030, the breakeven is 18 uses for emissions, 50 for water and more than 100 for plastic waste; for Scenarios A to C, 5 to 33 for emissions and 39 to 130 for plastic.

**SPI calculation:**  in the 2030 case, an item would need 6.9 times its modelled uses (18 against 2.6) to break even on emissions, 19.2 times (50 against 2.6) on water and more than 38.5 times (more than 100 against 2.6) on plastic waste. French dine-in, at 33.9 average uses, sits above the top of the reported emissions breakeven range of 5 to 33, which fits its near-neutral 9% emissions result.

SPI analysis

This is the core of the dispute between McDonald's and reuse policy. The company's figures do not say reuse fails; they say reuse fails at takeaway return rates. A regulator reading the same table would ask what return rates a pooled, multi-brand system could reach. SPI has not seen published return rates for a shared quick-service reuse pool at national scale.

## Scenarios: what the 10% takeaway target means in units

SPI translated the PPWR's 10% indicative 2030 target for take-away packaging (Article 33(5)) into reusable items per 1,000 takeaway items, using McDonald's own uptake and uses (Exhibit 11). The calculation counts items and uses only, so no currency enters it.

The table shows the trade-off in one line. Meeting 10% at McDonald's modelled 2.6 uses needs about 6.9 times as many reusable units as meeting it at 18 uses (38.5 against 5.6 per 1,000 takeaway items). Every extra use cuts the stock of plastic reusables, which is the driver of the plastic waste result in Exhibit 9.

A second calculation sizes the dine-in change. McDonald's says the PPWR affects more than 6,900 of its EU and EEA restaurants (October 2025). **SPI calculation:**  France's 1,630 restaurants at the end of 2025 are at most 23.6% of that figure, so at least about 5,270 McDonald's restaurants in the EU and EEA sit outside France's dine-in rule today. The six EU operated markets in Exhibit 1 hold 5,366 restaurants, at most 77.8% of the 6,900. The two figures come from different dates, the end of 2025 and an October 2025 report, so the shares are indicative.

## Other chains: a different route to the same rules

In practice: Restaurant Brands International.

RBI, owner of Burger King, Tim Hortons, Popeyes and Firehouse Subs, reports that as of December 2024, 90% of approved guest-facing fibre-based packaging across its brands came from recycled or certified sources, and that intentionally added PFAS were removed from about 97% of approved guest packaging volumes, against a goal of phasing them out by 2025 (RBI Packaging and Recycling page, consulted 25 October 2026). It reports EPS foam eliminated from approved guest packaging globally as of 2022, and a goal to cut virgin plastic in single-use guest packaging by 10% in the US and Canada by 2026. Its page records Burger King France piloting reusable cups and cutlery in one restaurant in 2021 and rolling them out nationally in 2022, Burger King UK removing dine-in soft drink lids in October 2022, and dine-in reusable cup pilots at Burger King UK and Finland in 2024.

In practice: McDonald's Netherlands and Germany.

The two optional models are the closest company data to the PPWR's takeaway offer. The Netherlands lets takeaway customers choose a reusable cup with a EUR 1 deposit return or a single-use cup; Germany offers single-use or reusable cups with reusable lids and a EUR 2 deposit return, for dine-in and takeaway (Purpose and Impact Report 2024 to 2025). Reported takeaway uptake was 4% and under 1% respectively (October 2025 report).

SPI analysis

RBI and McDonald's report on different bases, RBI on fibre-based packaging only and McDonald's on all primary guest packaging, so their percentages are not comparable and SPI does not rank them. Both chains report reusables in French dine-in service, and both report fibre as the base of their guest packaging.

## The United States: foam bans and EPR, not reuse

US rules reach quick-service packaging through format bans and producer responsibility, not reuse mandates (Exhibit 12). McDonald's had 13,706 US restaurants at the end of 2025, 95% franchised (Restaurants by Market 2025).

California's foam restriction is a recycling-rate test that failed. CalRecycle says producers had to show that all EPS met a 25% recycling rate by 1 January 2025 to keep selling, and "To date, this recycling rate requirement has not been met" (CalRecycle). The restriction binds producers; CalRecycle says businesses that are not producers, such as some retailers, distributors and restaurants, are not subject to it. For a franchised chain, the brand owner or licensee of a branded item may be its producer, according to CalRecycle's 26 August 2026 private-label guidance ([PR-US-005](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-005/)).

SB 54's longer arc matters more for fibre than for foam. Interim steps are a 10% source reduction in 2027, 30% recycling in 2028 and 20% reduction and 40% recycling in 2030, ahead of the 2032 targets ([PR-US-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-004/), citing CalRecycle). Oregon's SB 543 pairs its foam ban with a ban on foodware with intentionally added PFAS from 1 January 2025, which is the US parallel to the EU's food-contact PFAS limits ([PR-US-013](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-013/)).

SPI analysis

A US-EU chain carries two rulebooks for the same cup. In the US the questions are material and producer identity; in the EU they are channel, plastic share and reuse offer. The [retailer supplier rules piece](https://www.strategicpackaginginsights.com/insights/retailer-packaging-supplier-rules-compared/) shows how large buyers turn such rulebooks into supplier specifications.

## Industry reaction

> "We remain concerned that the PPWR requirement to offer reusables for takeout drives high risks for the environment"

***McDonald's** , quick-service restaurant company, [The Complex Reality of Reusable Packaging in Europe](https://corporate.mcdonalds.com/content/dam/sites/corp/nfl/pdf/McDonald%27s%20Report_The%20Complex%20Reality%20of%20Reusable%20Packaging%20in%20Europe_13.10.pdf), October 2025*

The report argues that renewable, recyclable and certified fibre packaging, with recycling and reduction, should remain part of the solution, and asks that evidence be weighed before operators must invest.

> "Final distributors of beverages and take-away food will have to offer consumers the option of bringing their own container."

***European Parliament** , co-legislator, [press release on the new EU packaging rules](https://www.europarl.europa.eu/news/en/press-room/20240419IPR20589/new-eu-rules-to-reduce-reuse-and-recycle-packaging), 24 April 2024*

The same release says those distributors will be required to endeavour to offer 10% of products in a reusable format by 2030, the figure the Commission Notice ties to Article 33(5).

> "Ils doivent donc obligatoirement faire usage d’une vaisselle réutilisable"
>
>
>
> **French Ministry of the Economy** , business guidance, [Entreprises, quels produits en plastique à usage unique vous sont interdits ?](https://www.economie.gouv.fr/entreprises/gerer-son-entreprise-au-quotidien/gerer-un-commerce/entreprises-quels-produits-en-plastique-usage-unique-vous-sont-interdits), 17 December 2025
>
>
>
> "Statewide sales and distribution restrictions are in place as of January 1, 2025."

In English: "They must therefore use reusable tableware"

***CalRecycle** , California's recycling regulator, [EPS Food Service Ware Requirements](https://calrecycle.ca.gov/packaging/packaging-epr/eps/), consulted 25 October 2026*

## What leaders should do now

1. **Packaging and procurement leads, by 12 February 2027:**  build a register of every guest pack by channel (dine-in, takeaway, delivery) and by plastic share of mass, and re-run it against the Commission's Annex V guidelines when they are published.
2. **Supplier quality teams, by mid-2027:**  obtain bills of materials for lined cups, coated wraps and lidded fibre bowls, because the 5% plastic line decides whether a fibre item is inside the 2030 dine-in ban.
3. **Operations leads in EU markets other than France, by 31 December 2027:**  cost the French dine-in model in each market, including dishwashers, storage and water, using the 33.9 uses McDonald's reports as a benchmark to beat, not an assumption.
4. **Takeaway and digital teams, before the takeaway offer applies:**  design an own-container and reusable option on terms no less favourable than single-use, and track uptake and returns by item, since McDonald's reports 1.5 to 2.6 uses and under 1% to 4% uptake.
5. **Public affairs and sustainability teams, by 3 July 2027:**  prepare evidence for the SUP Directive evaluation and national cup measures, including recycling rates for lined fibre cups.
6. **US compliance owners, now:**  confirm for each branded foam or PFAS-risk item who the producer is under California, Washington and Oregon rules, and keep evidence of non-EPS formats.
7. **Boards and investors, at the next budget review:**  ask for packaging cost and exposure split by dine-in and takeaway, because the rules and the economics differ by channel.

## Questions for your board

- Which of our dine-in items in each EU market contain more than 5% plastic by mass, and what replaces them by 1 January 2030?
- What uses per item does our reuse model need to break even on emissions and cost, and what do we achieve today?
- How will we offer takeaway reuse on equal terms, and who owns uptake and return rates?
- Where do franchisees carry the capital cost of washing and storage, and how is it shared?
- Do our 2025 packaging goal results, once published, separate fibre sourcing from plastic content?
- Who is the legal producer of our branded packaging in California, Oregon and Washington?

## What to watch

- **31 Dec 2026:**  the Commission's report on substances of concern in packaging is due, with PFAS limits already applying to food-contact packaging since 12 August 2026 ([PR-EU-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-002/)).
- **1 Jan 2027:**  California's 10% single-use plastic source reduction step under SB 54 ([PR-US-004](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/united-states/pr-us-004/)).
- **12 Feb 2027:**  Commission guidelines on Annex V under Article 25(6) and on beverages covered by reuse targets under Article 29(8) are due (Green Forum).
- **3 Jul 2027:**  the Commission's evaluation of the SUP Directive is due, including its coherence with the PPWR ([PR-EU-014](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-014/)).
- **2027:**  France's national reuse threshold rises to 10% ([PR-FR-001](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/france/pr-fr-001/)).
- **1 Jan 2030:**  PPWR Annex V point 3 dine-in ban, XPS added to the polystyrene ban, and the 10% indicative take-away target ([PR-EU-008](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-008/)).

## Methodology

- **Data used:**  McDonald's goal pages, Purpose and Impact Report 2024 to 2025, October 2025 reuse report and Restaurants by Market 2025; RBI's packaging page; the SPI Packaging Buyers Database McDonald's profile (42 companies in the database); SPI Regulation Tracker rule notes for the EU, France, Germany and three US states; official EU, French and Californian pages consulted on 25 October 2026.
- **PPWR sourcing:**  the HORECA and takeaway points are read from Commission Notice C/2026/3084, the European Parliament's Legislative Observatory summary and press release, and the Commission's pages, and each point in Exhibit 6 names its source. Article numbers appear only where one of those texts names them.
- **Counting rules:**  restaurant counts at 31 December 2025; company percentages as published; no currency is converted or summed, and deposits are shown in EUR for each scheme separately.
- **Calculations:**  breakeven multiples and reusable units per 1,000 takeaway items use only figures from McDonald's report and the 10% figure in Article 33(5). They are illustrations, not forecasts.
- **Cut-off:**  25 October 2026.
- **Limitations:**  company-modelled results are McDonald's and PwC UK's, not SPI's; SPI has not yet confirmed the Légifrance text of L. 541-15-10, the application dates of the PPWR takeaway duties, or McDonald's end-2025 results. This is not legal advice; check with counsel for any specific obligation.

## Sources

1. EUR-Lex, Commission Notice C/2026/3084, Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste (OJ C, 10 June 2026), sections 16, 17, 18, 22 and 27, [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:C_202603084](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=OJ:C_202603084), consulted 2026-10-25.
2. EUR-Lex, Directive (EU) 2019/904 on the reduction of the impact of certain plastic products on the environment (OJ L 155, 12 June 2019), [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L0904](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L0904), consulted 2026-10-25.
3. European Parliament Legislative Observatory, Regulation (EU) 2025/40 document summary, [https://oeil.europarl.europa.eu/oeil/en/document-summary?id=1802233](https://oeil.europarl.europa.eu/oeil/en/document-summary?id=1802233), consulted 2026-10-25.
4. European Parliament, New EU rules to reduce, reuse and recycle packaging, press release, 24 April 2024, [https://www.europarl.europa.eu/news/en/press-room/20240419IPR20589/new-eu-rules-to-reduce-reuse-and-recycle-packaging](https://www.europarl.europa.eu/news/en/press-room/20240419IPR20589/new-eu-rules-to-reduce-reuse-and-recycle-packaging), consulted 2026-10-25.
5. European Commission (DG ENV), Facts about the new EU rules on packaging and packaging waste, [https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste/facts-about-new-eu-rules-packaging-and-packaging-waste_en](https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste/facts-about-new-eu-rules-packaging-and-packaging-waste_en), consulted 2026-10-25.
6. European Commission Green Forum, PPWR implementation timeline and competent authorities, [https://green-forum.ec.europa.eu/packaging-and-packaging-waste-regulation-implementation_en](https://green-forum.ec.europa.eu/packaging-and-packaging-waste-regulation-implementation_en), consulted 2026-10-25.
7. economie.gouv.fr, Entreprises, quels produits en plastique à usage unique vous sont interdits ? (17 December 2025), [https://www.economie.gouv.fr/entreprises/gerer-son-entreprise-au-quotidien/gerer-un-commerce/entreprises-quels-produits-en-plastique-usage-unique-vous-sont-interdits](https://www.economie.gouv.fr/entreprises/gerer-son-entreprise-au-quotidien/gerer-un-commerce/entreprises-quels-produits-en-plastique-usage-unique-vous-sont-interdits), consulted 2026-10-25.
8. notre-environnement.gouv.fr, Quelles mesures nouvelles en 2023 pour mieux consommer en préservant l'environnement ?, [https://www.notre-environnement.gouv.fr/actualites/breves/article/quelles-mesures-nouvelles-en-2023-pour-mieux-consommer-en-preservant-l](https://www.notre-environnement.gouv.fr/actualites/breves/article/quelles-mesures-nouvelles-en-2023-pour-mieux-consommer-en-preservant-l), consulted 2026-10-25.
9. CalRecycle, EPS Food Service Ware Requirements, [https://calrecycle.ca.gov/packaging/packaging-epr/eps/](https://calrecycle.ca.gov/packaging/packaging-epr/eps/), consulted 2026-10-25.
10. McDonald's, Goal Performance and Reporting, [https://corporate.mcdonalds.com/corpmcd/our-purpose-and-impact/impact-strategy-and-reporting/performance-reports.html](https://corporate.mcdonalds.com/corpmcd/our-purpose-and-impact/impact-strategy-and-reporting/performance-reports.html), consulted 2026-10-25.
11. McDonald's, Packaging, Toys and Waste, [https://corporate.mcdonalds.com/corpmcd/our-purpose-and-impact/our-planet/packaging-toys-and-waste.html](https://corporate.mcdonalds.com/corpmcd/our-purpose-and-impact/our-planet/packaging-toys-and-waste.html), consulted 2026-10-25.
12. McDonald's, Purpose and Impact Report 2024 to 2025, [https://corporate.mcdonalds.com/content/dam/sites/corp/nfl/pdf/McDonalds_PurposeImpact_ProgressReport_2024_2025.pdf](https://corporate.mcdonalds.com/content/dam/sites/corp/nfl/pdf/McDonalds_PurposeImpact_ProgressReport_2024_2025.pdf), consulted 2026-10-25.
13. McDonald's, The Complex Reality of Reusable Packaging in Europe (October 2025), [https://corporate.mcdonalds.com/content/dam/sites/corp/nfl/pdf/McDonald%27s%20Report_The%20Complex%20Reality%20of%20Reusable%20Packaging%20in%20Europe_13.10.pdf](https://corporate.mcdonalds.com/content/dam/sites/corp/nfl/pdf/McDonald%27s%20Report_The%20Complex%20Reality%20of%20Reusable%20Packaging%20in%20Europe_13.10.pdf), consulted 2026-10-25.
14. McDonald's, Restaurants by Market 2025, [https://corporate.mcdonalds.com/content/dam/sites/corp/nfl/pdf/Restaurants%20by%20Market%202025.pdf](https://corporate.mcdonalds.com/content/dam/sites/corp/nfl/pdf/Restaurants%20by%20Market%202025.pdf), consulted 2026-10-25.
15. Restaurant Brands International, Packaging and Recycling, [https://www.rbi.com/English/sustainability/planet/packaging-and-recycling/default.aspx](https://www.rbi.com/English/sustainability/planet/packaging-and-recycling/default.aspx), consulted 2026-10-25.
16. SPI Regulation Tracker, rules PR-EU-001, PR-EU-002, PR-EU-006, PR-EU-008, PR-EU-014, PR-FR-001, PR-FR-002, PR-FR-003, PR-DE-002, PR-US-004, PR-US-005, PR-US-012 and PR-US-013, /data/packaging-regulation-tracker/european-union/ and /data/packaging-regulation-tracker/france/, consulted 2026-10-14.
17. SPI Packaging Buyers Database, McDonald's profile, /data/packaging-buyers-database/, consulted 2026-10-14.