PPWR & B2B Transport Packaging: New Obligations, Deadlines and the Path to Reuse

What is the PPWR?

PPWR stands for Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40. It aims to reduce packaging waste, promote reuse, and improve the recyclability of packaging.

The regulation covers packaging of all materials. This also applies when packaging is used exclusively between businesses and never reaches private consumers. A transport box for components or a pallet for production material is therefore just as much in scope as sales packaging.

The PPWR has applied since August 12, 2026. It is directly applicable in all 27 member states and did not need to be transposed into national law first. Some requirements start later, however, including the reuse targets from 2030. Using single-use packaging today is therefore not automatically unlawful. What matters is the specific packaging, how it is used, your company’s role, and the deadline that applies.

Alongside the regulation, national law applies. Registration, records, and fines are governed by it, and each member state has its own rules.

Which transport packaging is affected?

Transport packaging is the packaging that carries your goods between plant, warehouse, and customer. It makes handling and transport easier and protects goods from transport damage. Sales packaging used for transporting products is covered as well, expressly including products distributed via e-commerce. For the reuse targets, the regulation lists the formats concerned:

• pallets
• foldable plastic boxes
• boxes
• trays
• plastic crates
• intermediate bulk containers
• pails
• drums
• canisters

Each “of any size or material,” as well as pallet wrappings and straps (Art. 29(1)).

Two words in that phrase are decisive. “Or material” means that the single-use wooden pallet is covered as well. It counts toward the total against which your target is measured.

One distinction is especially important here: Being covered by the PPWR does not mean having to meet every single requirement.

Cardboard boxes are an example. Boxes made of paperboard or cardboard are exempt from the reuse targets for transport packaging (Art. 29(4)(d)). That does not exempt it from the PPWR as a whole, because other requirements such as conformity and, in the future, recyclability still need to be checked.

Cardboard is not the only case. The same paragraph exempts three more groups, and all three directly affect B2B shipments: packaging for dangerous goods under Directive 2008/68/EC (point (a)), packaging for large-scale machinery, equipment, and commodities that is custom-designed to fit the individual requirements of the economic operator that placed the order (point (b)), and flexible formats in direct contact with food and feed (point (c)). Check these three before you determine your baseline.

It also matters how these exemptions work. Exempt formats do not appear in the calculation at all, neither in the numerator nor in the denominator. Switching to cardboard therefore does not meet the target; it only shrinks the volume on which the target is calculated.

Which deadlines apply when?

Date	What happens	Reference
August 12, 2026Already passed	The PPWR applies. Requirements for substances in packaging, conformity assessment with EU declaration of conformity, registration, participation in a reuse system, and marking for identification take effect	Art. 5, 15, 26, 27, 44
August 12, 2028	Harmonized material label, at the earliest. Transport packaging is exempt	Art. 12(1)
February 12, 2029	Reuse label and QR code, at the earliest, only for newly placed units. Open loop systems without a system operator are exempt	Art. 12(2) and (3)
January 1, 2030	40% reuse target, plus a full reuse obligation within a group of companies and within the same member state	Art. 29(1) to (3)
	10% reuse target for grouped packaging in the form of boxes, excluding cardboard	Art. 29(5)
	Minimum recycled content in plastic packaging, as a rule 35% for load carriers, calculated as an average per manufacturing plant and year. Plus the 50% empty space rule	Art. 7(1)(d), Art. 24(1)
January 1, 2040	Best-effort target of 70% for the same formats as in 2030. Not a hard obligation; the regulation says “shall endeavour”	Art. 29(1), second subparagraph
	Best-effort target of 25% for grouped packaging in the form of boxes	Art. 29(5), second subparagraph
	Minimum recycled content rises to 65% for the same group as in 2030. Unlike the first stage, without a postponement clause	Art. 7(2)(d)

Four of these dates are moving floors: the two labeling obligations, the minimum recycled content, and the empty space rule. For each of them, the regulation sets a second condition, namely a period of 24 or 30 months or three years after the entry into force of the related implementing act. Whichever date is later applies. These acts have not yet been adopted, so the four dates may move back.

For recycled content, however, only the first stage can move. The second follows in 2040 at 65% and is set without that condition (Art. 7(2)(d)). It is tied to placing on the market: it covers packaging placed on the market from January 1, 2040. The provision contains no obligation to retrofit containers that were placed on the market earlier. If you are procuring a plastic fleet today that is meant to run for twenty years, the figure is therefore a consideration for long-term procurement, for example for additional purchases and replacement containers from 2040. Two exemptions belong to this rule. Plastic parts representing less than 5% of the total weight of the whole packaging unit are exempt from both stages (Art. 7(5)(b)). The Commission interprets “plastic parts” in line with the definition of composite packaging, and the manufacturer must substantiate the exemption in the technical documentation (Commission guidance C/2026/3084, Section 7; Art. 3(1)(24)). The second exemption concerns food contact and rarely applies to B2B transport.

The reuse target under Art. 29(1) has no such clause. January 1, 2030, stands there without a condition, and that is the date this article is about.

What can move, by contrast, is the obligation to demonstrate that the target has been met. It applies from January 1, 2030, or 18 months after the entry into force of the implementing act on the calculation methodology, whichever is later (Art. 30(4)). That does not change the recommendation: if you have not counted in 2030, you cannot make up for it afterward.

Does this apply to you? Four roles that are decisive for your reuse planning

Which obligations apply to you is not decided by your contract alone but by the role you actually take on for each type of packaging.

• User of the packaging: You use transport packaging in your own flow of goods. The reuse targets from 2030 are addressed to you (Art. 29(1) PPWR).

• Producer within the meaning of the regulation: You make packaging available for the first time in a member state, expressly also when it is reusable and when it is empty. Registration and extended producer responsibility depend on this role. The exact allocation depends on the type of packaging, where you are established, and the delivery route (Art. 3(1)(15), Art. 44, Art. 45 PPWR).

• Manufacturer: You have packaging designed or manufactured under your own name or trademark, regardless of whether any other trademark is visible on it. Conformity assessment, technical documentation, and the EU declaration of conformity depend on this role (Art. 3(1)(13), Art. 15 PPWR). For micro-enterprises that have packaging designed or manufactured under their own name or trademark and whose packaging supplier is located in the same member state, the special rule in Art. 3(1)(13)(b) PPWR applies.

• Importer: Anyone established in the EU who places packaging from a third country on the market here must first ensure that the manufacturer has carried out the conformity assessment and that the packaging is labeled correctly (Art. 3(1)(17), Art. 18(2) PPWR). An importer that places packaging on the market under its own name or trademark is considered the manufacturer (Art. 21 PPWR).

What does not apply to transport packaging right now?

Some things are currently circulating as obligations that do not apply to load carriers in that form. Sorting them out early saves you work.

• The harmonized material label, i.e., the pictogram for disposal, expressly excludes transport packaging. Packaging that is subject to a deposit and return system is excluded as well. Of these two groups, only e-commerce packaging remains subject to the obligation (Art. 12(1)). A separate label for packaging subject to deposit and return systems, required by the same paragraph, must be kept apart from this (Art. 12(1), fourth subparagraph).

• The reuse label with QR code applies at the earliest from February 12, 2029, to newly placed reusable packaging (Art. 12(2)). Open loop systems that do not have a system operator are exempt (Art. 12(3)). The Commission gives the Euro pallet as an example. An open loop system with an operator, on the other hand, is covered. Whether containers already in circulation must be retrofitted depends on the date they were placed on the market. You will find this below under your existing stock.

• The 50% empty space rule exempts reusable packaging within a reuse system (Art. 24(5)). In practice, it therefore applies to single-use formats.

• Your existing stock is treated according to when it was placed on the market:

  • Reusable packaging placed on the market before February 11, 2025: The obligation to bring it into conformity, withdraw it, or recall it expressly does not apply (Art. 15(9)). According to the Commission’s interpretation, you do not have to retrofit it. It may remain in circulation until it is removed from the reuse system due to functional obsolescence or operational limitations (Commission guidance C/2026/3084, Section 14).

  • Reusable packaging placed on the market between February 11, 2025, and the start of the label obligation, i.e., at the earliest February 12, 2029: According to the Commission’s interpretation, it should bear the reuse label under Art. 12(2) by February 2032 at the latest (Commission guidance C/2026/3084, Section 14). This does not apply in open loop systems without a system operator (Art. 12(3)).

  • Packaging produced before August 12, 2026, and still held in stock: According to the Commission’s interpretation, it does not have to be destroyed, remanufactured, or relabeled. The identification and manufacturer information under Art. 15(5) and (6) may then be provided in an accompanying document. This also applies to reusable packaging already placed on the market (Commission FAQ, August 2026).

  This concerns the containers themselves. The reuse target, by contrast, is tied to the packaging used, not to placing on the market (Art. 29(1)). Your existing stock therefore counts toward the calculation.

What changes for reuse from 2030?

The reuse target is the share of your transport packaging that must run in a reuse system. From January 1, 2030, this share is at least 40% of the listed formats. It is an overall target across these formats combined, so you do not have to bring each format group to 40% individually. The obligation does not fall on your pallet supplier but on the economic operator that uses the packaging (Art. 29(1)). As a rule, that is the company that ships the goods on it. If you have goods collected ex works or use service providers, it is best to settle the allocation of roles by contract.

Alongside the 40% target there is a second, smaller one. Anyone who uses grouped packaging in the form of boxes outside of sales packaging to group products into a stock-keeping or distribution unit must, from January 1, 2030, keep at least 10% of it as reusable packaging within a reuse system. Cardboard boxes are excluded here too (Art. 29(5)). For 2040, the same paragraph sets 25%, again as a best-effort target. This target has its own baseline and is calculated separately (Art. 30(1)).

In two cases, the regulation sets no percentage at all but a full reuse obligation:

• Within your own group: transport between different sites of the same company and to linked enterprises and partner enterprises, throughout the EU. What counts as a linked enterprise is determined by EU Recommendation 2003/361/EC (Art. 29(2)).
• Within the same member state: deliveries to other companies in the same member state (Art. 29(3)).

For a company with several plants, this is the more far-reaching part. Transport between production and a central warehouse falls under paragraph 2, deliveries to a customer in the same member state under paragraph 3.

For pallet wrappings and straps, the Commission has adopted an exemption from these two 100% requirements. It does not remove the general 40% target. “Films and straps are completely exempt” would therefore be a wrong conclusion (Commission Delegated Decision (EU) 2026/429, Art. 1 and recital 1).

For your operations, this means: check not only the material but also which packaging is used on which route between which parties. The calculation methodology will be specified in an implementing act that must be adopted by June 30, 2027. That deadline is still running (Art. 30(3)).

Why the number of uses decides the target

Most overviews leave out this point. According to the recitals of the regulation, the targets for transport packaging are calculated “as a percentage of number of times used” (recital 94). What counts is how often packaging is used, not how many containers you have bought.

This makes the target a usage target, not a procurement target. A single-use pallet delivers exactly one use. A reusable pallet in a system delivers as many uses as it completes rotations.

Why reusable packaging alone is not enough

A container that can be used many times is only the start. For reuse to work in practice, it must come back after it has been emptied, be inspected, and be cleaned or repaired where necessary. Then it has to be available again where the next filling takes place.

The PPWR takes exactly this into account. Reusable packaging counts only “within a re-use system.” A reuse system is the organized loop behind reusable packaging, not the container itself. Annex VI describes what belongs to it: return and collection of the containers, rules for use and storage, reconditioning before the next use, and an organization that is responsible for all of it.

• Whoever makes reusable packaging available for the first time must ensure that such a system is in place. Using an existing one expressly counts as compliance (Art. 26(1)).
• Whoever makes use of reusable packaging participates in one or more reuse systems (Art. 27(1)) and ensures that the containers are reconditioned before they are offered again for use by end users (Art. 27(2)). Reconditioning means assessing the condition, removing damaged components, cleaning and washing, repairing, and inspecting and assessing fitness for purpose (Annex VI, Part B, point 2).
• In a closed loop system, a third obligation applies. You return the containers to collection points identified by the system participants and approved by the system operator (Art. 27(4)), and returning them to a location of your own choosing does not meet this obligation.

In practice, you should therefore have clear answers to these questions:

• Who collects empty containers and organizes the return?
• Who checks condition and cleanliness and takes care of reconditioning?
• How are losses, damaged containers, and fluctuations in demand handled?
• What information and records do the companies involved provide?
• Does ownership of the packaging change, or does it circulate without a change of ownership?

This last question decides whether you operate in a closed loop or an open loop system (Annex VI, definitions, points (b) and (c)). It determines which obligations under Annex VI remain with you.

Data collection also depends on the system. Every reuse system needs rules that allow access to the number of rotations, return rates, and rejects (Annex VI, Part A, point 1(f)). These provisions require access to the data, not its reporting. Open loop systems without a system operator are exempt from this point (Annex VI, Part A, point 1), as they are from the label (Art. 12(3)). If you use an open loop system that already existed before the regulation entered into force, a second, more far-reaching exemption in the same section applies, regardless of whether the system has an operator. The Euro pallet exchange falls under it. A blanket statement that every reusable container must already be tracked digitally on an individual basis therefore falls short. For identification, a type, batch, or serial number or another element is sufficient (Art. 15(5)). This provision does not require a separate serial number for each individual item or tracking of each item. You still have to report, just elsewhere: if you are subject to the reuse targets, you submit a report on the achievement of your targets to the competent authority for each calendar year, first for 2030 and each time within six months after the end of the year (Art. 31(1) to (3)).

What does this mean if your company is not yet prepared?

A lack of preparation can be costly and put your ability to deliver at risk. The following figures apply in Germany and illustrate the order of magnitude. Check the rules in your own member state.

The upcoming reuse targets are binding as well.

For certain infringements, the PPWR first provides for a procedure to remedy the non-compliance. National penalties that already apply remain unaffected. If an authority finds an infringement, it must first require the company to put an end to it (Art. 62(1)). Further measures follow only if the infringement persists.

What those measures look like depends on the type of infringement. If only the paperwork is wrong, for example if the EU declaration of conformity is missing, and the problem persists after the request, the member state takes all appropriate measures: it can prohibit the packaging from being made available on the market or ensure that it is recalled or withdrawn (Art. 62(2)). For substantive infringements such as a missed reuse target, the regulation instead refers to the penalties under national law (Art. 62(3)). Fines are a mandatory part of these penalties (Art. 68(2)). Art. 62 does not expressly provide for a market withdrawal for this group of infringements. Other market surveillance measures remain unaffected.

Review your registration, responsibilities, and records now, and then plan how to implement the reuse targets.

Four steps to the right solution

1. Map your packaging and flows of goods

Start with an overview: Which packaging do you use, in what quantities, and on which routes? Record not only the main container but also additional packaging such as films, straps, and cartons. Note whether goods go to your own sites or to external customers, because that determines whether the target or the full obligation applies.

2. Assign obligations and gaps

For each use case, check the applicable requirements, deadlines, and exemptions. Clarify with your suppliers which packaging information and conformity documents are available. Where your company is the manufacturer within the meaning of the regulation, suppliers must provide you with the information and documentation you need to demonstrate conformity (Art. 16(1)). If you are only a user of the packaging, this is a matter of contract, not of the regulation. Separate missing documents from processes that only need to change by 2030.

3. Test a suitable flow of goods

Choose a regularly served connection with clear contacts. Test the right reusable load carrier and the entire return flow there. Check product protection, handling, hygiene, storage requirements, and availability under real conditions. Record the number of rotations per container from the start, because that is exactly the figure that will later demonstrate your target.

4. Compare total costs and scale up

Do not just compare the purchase price of single-use packaging with the price of a reusable trip. Also take into account labor time, disposal, return transport, cleaning, losses, and storage space. On that basis, you can decide which other flows of goods are suitable for the switch.

How RECALO supports you in switching to reuse

If you want to introduce reusable packaging, you do not necessarily have to buy your own container fleet and build all the container logistics yourself. One option is pooling: you use load carriers while a service provider takes over the related processes.

The regulation expressly provides for this route. Users may appoint a third party that is responsible for one or more mutualized reuse systems. In that case, “the obligations set out in this Article shall be met by that third party on their behalf” (Art. 27(3)). What you can hand over is the operation of the system. Whether a provider can take on this role depends on whether its system meets the requirements of Annex VI.

RECALO provides reusable load carriers and also offers their transport and collection as well as cleaning, maintenance, quality management, and container management.

Whether a solution fits your company depends on factors such as your products, volumes, sites, and hygiene requirements. The legal assessment also covers the specific packaging, records, and responsibilities. Pooling can support implementation, but it does not replace this assessment.

Three things remain with you in any case:

• Your sales and primary packaging, which forms a separate set of obligations with its own deadlines. The requirements for your packaging continue to follow the applicable provisions (Art. 5, 7, 12, and 15 PPWR).
• Your own registration and quantity reporting, to the extent you are responsible for them. A pooling contract alone does not transfer these obligations. Reusable packaging is not generally exempt from extended producer responsibility either. Germany The VerpackDG governs registration as well as take-back and records; appointing a producer responsibility organization is governed separately (Section 6(1) and (2), Section 39(1), first sentence, No. 6, (3) and (6) VerpackDG). Check the rules of each member state in which you make packaging available.
• The target itself, because it applies to you as the user. A system supports you with countable uses and the related data; meeting your reuse targets remains your responsibility (Art. 29(1) to (3) PPWR).