A coffee meeting or a quick bite at Schuman roundabout, an afterwork drink at Plux or a conference in a hotel on Arts-Loi: EU policy makers are well placed to know that our lives revolve around the hospitality industry and the diversity of services it has to offer. 89% of our businesses are micro-enterprises, mostly family-owned, contributing to employment, growth, and economic prosperity in Europe.
The European Commission’s intent to reduce and prevent waste in the Packaging and Packaging Waste Regulation (PPWR) is in line with the hospitality industry’s commitment to achieve a green and circular economy. As other industry stakeholders, we are convinced that reuse and recycling must go hand in hand.
Since 2022, HOTREC has called to preserve the coexistence of single-use and multiple-use packaging systems – considering the heterogenous nature of the hospitality industry: whether our establishments are based in remote areas, touristic hubs or rely on regular customers; whether it is a small salad bar, a brasserie; whether our operators are based in countries with efficient recycling streams. Their needs for packaging vary.
Switching to reuse and refill cannot happen overnight
Switching to reuse will require a systemic change in our industry’s operations. Establishments will have to source sustainable reusable packaging, invest in setting up cleaning and storage facilities and dedicate space that limits revenue potential within their premises. Staff will also need to be trained accordingly. The impact of such measures has not been assessed.
Do not assume reuse is always the best option in HORECA
Encouraging the use of reusable cups is one thing. But applying blanket bans to all types of single-use in all establishments is another! In the hospitality industry, efficient collection of single-use for recycling might lead to less carbon emissions than automatically switching to resource and energy intensive reuse systems. And sorry to disappoint but reusable packaging is not always better for the environment.
Single-use packaging in HORECA is not superfluous
Packaging used in hospitality has many functions: From extending shelf life to limiting waste or avoiding food contamination. There is sometimes no other way to fulfil all those functions. If single-use bans were to be maintained in PPWR, we urge EU co-legislators to consider exemptions for single-use packaging that delivers a better overall environmental and climate outcome. We also ask EU co-legislators to consider exemptions when duly justified by concerns related to food safety and food waste.
Single-use helps tackle food waste
Single-serve portions of food like cheese, butter or other food items, help reduce food waste by providing the right amount to consumers. It also helps limit the amount of time foodstuffs are displayed at room temperature with air contact, for instance, on a breakfast buffet. Tackling food waste in our industry is a long-haul priority and in line with the European Commission’s proposal to establish EU food waste reduction targets by 2030. Investments to reducing food waste should not be compromised by circular economy initiatives, including PPWR. EU policy makers bear the ultimate responsibility of balancing such conflicts.
Drop the knife edge approach on hotel cosmetics!
Hoteliers across Europe have started to phase out miniature hotel amenities, a staple part of the traditional hotel experience, in favour of sustainable and innovative packaging solutions. Beyond aesthetic, cosmetics dispensers in hotels must ensure hygiene, safety and avoid germs from penetrating the product. Since COVID, sensitive areas such as bathrooms face stricter requirements to protect guests from contamination. Tremendous research is done to provide sustainable, hygienic, and cost-effective cosmetic systems with sealed, tamper and theft proof systems. These market developments should not be discouraged by EU law makers.
Limit the ban to miniature cosmetics
The Council’s position – which foresees an extension of the ban on miniature hotel cosmetics to all single-use dispensers – will condemn European hoteliers. It will leave them with little to zero options apart from switching to refill. To date, refilling cosmetic systems are lacking on the market and nowhere near ready to upscale. While some exclusive hotels have successfully implemented costly refilling systems, most of our businesses do not have the capacity nor the resources to invest in high quality systems ensuring minimum hygiene and safety standards. Refilling cosmetic systems in hotel bathrooms can also pose a problem of liability.
Bring certainty and substantial transition periods
Finally, our businesses need harmonisation, clear definitions, and certainty on what products to rely on or not. Will recyclable coffee capsules be allowed in hotel rooms? Will sachets of sauces be accepted in hotel room service? Hospitality operators cannot wait for secondary legislations to clear doubts and answer numerous interrogations. Substantial transition periods for businesses are essential.
HOTREC is not asking EU policy makers to backtrack but rather deliver a clear and solid PPWR yet able to pass the hospitality reality check.
By Marie Audren, Director General of HOTREC (Hospitality Europe)


