When do the PPWR reuse targets for transport packaging apply?

From 1 January 2030, or 18 months from the entry into force of the implementing act on the calculation of the reuse targets under Article 30(3), which has to be adopted by 30 June 2027. The Commission's own news item of 25 February 2026 states the 40% target for transport and sales packaging as applying from 1 January 2030.

Which packaging formats do the PPWR transport reuse targets cover?

The Commission lists pallets, foldable-plastic boxes, boxes, trays, plastic crates, intermediate bulk containers, pails, drums and canisters, including pallet wrapping and straps. The Commission's PPWR FAQ adds that Article 29(1) is an exhaustive list, so a format that is not in it is not covered, and that Article 29(4)(d) exempts cardboard boxes, including corrugated cardboard boxes.

Is returning a pallet enough to comply with the PPWR reuse rules?

No. Under Article 27, economic operators using reusable packaging must participate in one or more reuse systems that meet the requirements in Annex VI, Part A, and must ensure those systems comply. The Commission's FAQ says operators may also set up their own reuse system, and that a system operator is not a legal requirement.

Does the PPWR require real-time tracking of every pallet?

Not per se. The Commission's FAQ states that open-loop reuse systems without a system operator are exempted from the reuse labelling requirements and from reporting on the number of rotations achieved (Annex VI, Part A, section 1(i)). A trade report of 2 October 2026 adds that the PPWR does not require every company to track every individual pallet in real time, and that the requirement is to demonstrate compliance.

KontorBund — Note PPWR reuse targets for pallets and transport packaging
Last checked 4 October 2026
kontorbund.com/notes/ppwr-transport-packaging-reuse.html

The Library

PPWR reuse targets: pallets and transport packaging, 40% by 2030 and 70% by 2040

Last checked4 October 2026

KeeperOpen — keeper wanted

StatusFrom 1 January 2030

The short version

The PPWR does not stop at the box on a consumer's doorstep. It covers transport packaging — pallets, plastic crates, boxes, trays, intermediate bulk containers, pails, drums and canisters — and puts reuse targets on it: at least 40%, reusable and part of a reuse system, from 1 January 2030, according to the Commission's own news item of 25 February 2026. Trade press puts the second step at 70% from 1 January 2040 — that figure is press-sourced only. The date is also softer than it looks: the Commission's FAQ dates the reuse targets to 1 January 2030 or 18 months after the entry into force of the calculation act under Article 30(3), due by 30 June 2027. And returning a pallet is not compliance: what the Regulation asks for is participation in a functioning reuse system.

How this page is sourced. The Commission's packaging-waste page and its news item of 25 February 2026 are official. So is the Commission's PPWR FAQ — which describes itself as the views of its authors and not binding law. Where a sentence rests on the trade report of 2 October 2026 rather than on either of those, we say press and mark it: that report carries no article numbers, so nothing here should be quoted at a supplier or an authority without checking it against Regulation (EU) 2025/40 first.

What applies, and when

Two dates get confused and both matter. The Regulation applies since 12 August 2026. The reuse targets it contains do not — and their start date is not a single clean day either.

The instrument: Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), in force since 11 February 2025, application date 12 August 2026 — the Commission's own wording on its packaging-waste page.
Reuse targets — Article 29: Per the Commission's news item of 25 February 2026: from 1 January 2030 economic operators in the EU must ensure that at least 40% of transport and sales packaging is reusable, applying to formats such as pallets, foldable-plastic boxes, boxes, trays, plastic crates, IBCs, pails, drums and canisters, including pallet wrapping and straps.
The date can move: The Commission's PPWR FAQ, chapter X question 2, puts the reuse targets at "from 1 January 2030 or 18 months from the date of entry into force of the implementing act on the calculation of reuse targets, referred to in Article 30(3), to be adopted by 30 June 2027". That act is not adopted yet, so the second of the two dates cannot be calculated today.
Reusable packaging already applies: The FAQ says the reusable-packaging provisions (Article 11) apply from entry into force, 11 February 2025 — but the minimum number of rotations will be complied with only from the date set in the act under Article 11(2), to be adopted by 12 February 2027. Until that act exists, there is no number to design against.
Who checks it: The FAQ says compliance with the minimum number of rotations is verified by Member States' market surveillance authorities, under Article 62(1), point (h).

"40% by 2030" is true and incomplete. The percentage is the Commission's; the possibility of a later start is the Commission's too. If you see a supplier, a consultant or a trade piece assert a hard 2030 deadline with no mention of the Article 30(3) act, the first thing missing is the calculation method — the thing your percentage would be measured with.

What counts as transport packaging

The Regulation reaches transport packaging, not only the packaging a consumer takes home. The Commission's own list, from the news item of 25 February 2026, is:

The Commission's list, verbatim

Formats "such as pallets, foldable-plastic boxes, boxes, trays, plastic crates, intermediate bulk containers, pails, drums, and canisters, including pallet wrapping and straps".

Trade summaries render the same list in the vocabulary you will meet on a loading dock — pallets, collapsible plastic crates, boxes, trays, IBC containers, buckets, drums and jerry cans (press, 2 October 2026). "Pails" and "buckets", "canisters" and "jerry cans": same formats, two vocabularies. Neither list is a threshold — the FAQ says Article 29(1) is an exhaustive list of the formats covered by the reuse targets, so a format that is not on it is not in scope in the first place.

Cardboard boxes are exempt: The FAQ, chapter XIII question 6: Article 29(4)(d) "exempts cardboard boxes from the scope of the reuse targets", and that includes corrugated cardboard boxes. The exemptions list is to be read strictly and is limitative, in terms of material, format and use.
Interlayers are simply not covered: Same answer: the cardboard exemption does not extend to interlayers, but interlayers are not a format listed in Article 29(1) either, so they are not concerned by the reuse targets "in the first place".
Flexible formats can still be in: The FAQ, chapter XIII question 7: Article 29(4)(c) excludes flexible transport formats in direct contact with food and feed. So big bags or flexible IBCs not used for direct food contact, not carrying dangerous goods and not custom-designed for large-scale machinery should comply with the targets in Article 29(1) to (3).
Wrappings and straps are two formats, not one: FAQ, chapter XIII question 8: they are different packaging formats, but "may be part of the same transport unit for the purpose of calculating compliance with reuse targets under Article 29".
"Transport unit" is not defined: FAQ, chapter XIII question 10: the term is not defined nor used in the Regulation, and "might be defined in the future" in the rules on calculating achievement of the reuse targets under Article 30(3).

The two numbers

This is where the sourcing splits, and it is worth being blunt about it. The 40% is official. The 70% is not — as far as we could establish on 4 October 2026, it exists in trade reporting and in nothing we could read from the Commission.

40% — from 1 January 2030: Official. The Commission's news item of 25 February 2026: "from 1 January 2030, economic operators in the EU must ensure that at least 40% of transport and sales packaging is reusable". Note the Commission's phrasing covers transport and sales packaging; the trade report describes the same target as covering transport packaging. We could not read the Regulation to settle which wording is the operative one.
70% — from 1 January 2040: Press only. The trade report of 2 October 2026 says that from 1 January 2040 businesses are "expected to work towards" reusable packaging within a reuse system for at least 70% of the transport packaging covered. Two things to hold onto: no article number, and softer wording than the 2030 target. We found no Commission document stating the 2040 level.
The Commission can lower the bar: FAQ, chapter XIII question 16: the Regulation empowers the Commission to adopt delegated acts supplementing the reuse targets for transport packaging, grouped packaging and beverages — but only under strict conditions and where necessary in the light of scientific and economic developments, to exempt economic operators facing particular economic constraints or specific packaging formats where the targets are hindered by hygiene, food safety or environmental issues, after an impact assessment.
And it has used that power once: 25 February 2026: the Commission adopted a delegated act exempting wrapping and straps used to secure goods on pallets from the EU's 100% reuse requirement — described by the Commission as the first application of a delegated act under the law. See the next section.

We are not going to launder the 70% into an official figure. It is the kind of number that gets repeated until it looks sourced. If you need it internally, treat it as an expectation to plan against, not a rule you can be measured on today — and read what we could not establish.

The stricter flows, and where 100% comes from

The 40% is an average over a population of packaging. Not every flow is allowed to sit inside that average: the Regulation singles out packaging that moves inside one organisation — and the target there is not 40%.

The clearest official statement of the 100% is the Commission's own explanation of why it exempted two formats from it:

The Commission, on pallet wrapping and straps

"The Packaging and Packaging Waste Regulation (PPWR) had previously set a 100% reuse target for the two items when used within companies and between companies in the same Member State, but both items will now be exempt from this rule."

That is the Commission's news item of 25 February 2026, and it confirms three things at once: transport packaging reuse targets include a 100% tier; that tier attaches to intra-company flows and to deliveries within a single Member State; and the Commission can carve formats out of it. The background it gives is a study concluding that exclusive use of reusable pallet wrappings and straps for those flows could lead to disproportionate adaptation costs. Draft feedback ran from 10 December 2025 to 9 January 2026.

The trade report of 2 October 2026 (press) describes the same tier in slightly wider terms: from 2030, transport packaging moving between sites belonging to the same company or between related companies must be reusable and used within a reuse system, and the same applies to deliveries to another company within one member state. We found no Commission wording that mentions "companies in the same group" — only the "within companies" and "same Member State" phrasing above. Treat the group limb as unconfirmed.

What the exemption actually exempts. The wrapping and the strap — not the pallet. The Commission says the exemption "ensures operators can meet the overall 40% reusability target without facing undue burdens associated with specific packaging components". So a palletised load is not out of scope because the film around it is; that is the distinction that gets lost when this is passed along as "pallet packaging is exempt".

Returning a pallet is not compliance

This is the part of the topic that survives translation into a one-person business, and it is also the part the trade reporting gets most right. The requirement is not "use the asset more than once". It is participation in a reuse system.

What Article 27 requires: FAQ, chapter XIII question 3: economic operators using reusable packaging must participate in one or more reuse systems and ensure those systems comply with the requirements in the PPWR, Part A of Annex VI. They may also set up their own reuse system, which must meet the same requirements — the regulation sets minimum requirements and "the sector needs to find ways to cooperate".
What a reuse system is not: It does not have to cover a whole Member State. FAQ, chapter XIII question 4: systems range from local to multi-country, but must provide equal access and fair conditions to the end users in the area in which they operate.
What "functioning" means in practice: Press (2 October 2026): before packaging goes back into service it must be prepared for its next use, and businesses need data showing how packaging is used, returned, repaired and put back into circulation — rather than a pallet that merely goes back to its owner from time to time. That sentence is the trade report's reading, not a quoted provision.
Two named examples: FAQ, chapter XIII question 2, gives open-loop systems: the German 0.33 litre longneck reusable bottle system, and — the one that matters here — the Euro Pallet: a standard, licensees for production, an association (EPAL) doing licensing and some services, and no system operator or system management. The Commission's own example of a reuse system is therefore the pallet pool most EU businesses already use.
EPR does not go away: FAQ, chapter XIII question 5: EPR obligations apply to all producers placing packaging on the Union market, single-use or reusable. The obligation stays with the producer of the reusable packaging, while the reuse system must have procedures ensuring EPR obligations are implemented for the packaging in it (Annex VI, Part A, point 1(i)).

Pooling, third parties, and what is not required

This is where three claims circulate that the sources do not support, and the Commission's own FAQ is the reason we can say so.

Pooling is an option, not an obligation: FAQ, chapter XIII question 2, in the Commission's own words: systems "are often coordinated by a system operator, who manages the logistics and ensures quality, even if the existence of a system operator is not a legal requirement under the PPWR". That is as close to a flat statement as you get. The trade report says the same in commercial language (press): pooling is one way to manage reusable assets centrally, and "that does not make pooling a legally required solution".
Responsibility can sit with a third party: Press (2 October 2026): the Regulation allows responsibility for operating one or more shared reuse systems to be assigned to a third party, and a pooling operator's centralised asset management can make returns, repairs and data easier. We found no Commission wording for the assignment sentence — it is the trade report's, and it is the kind of arrangement that would need to be written into a contract rather than assumed.
No real-time tracking of every pallet: Press (2 October 2026): "This does not mean that the PPWR requires every company to track every individual pallet in real time. The key requirement is to demonstrate compliance with the reuse rules." The FAQ supports the direction from the other end — see the next row.
The rotation-reporting relief in the FAQ: FAQ, chapter XIII question 1: closed-loop systems with a system operator must report the number of rotations or trips per individual reusable packaging, or an average estimate where per-item calculation is not feasible. Open-loop systems without a system operator are exempted from that obligation (Annex VI, Part A, section 1(i)) — and from the reuse labelling requirements too. An implementing act under Article 12(6) will specify when individual QR-code tracking is considered not feasible.

Which is the practical question to ask. Not "do I need a pooling operator", but "which system is this packaging in, and who operates it" — because Article 27 binds you to participate in a system that complies with Annex VI, and the exemption from rotation reporting depends on whether a system operator exists.

Does this reach a one-person shop?

Largely not — if we take the Commission's own format list at face value. Pallets, foldable-plastic boxes, trays, plastic crates, IBCs, pails, drums and canisters are not the packaging a sole trader posting single parcels buys. The transport packaging in a parcel operation is the cardboard box, and the FAQ says cardboard boxes, corrugated included, are exempt from the reuse targets under Article 29(4)(d).

That is the honest answer for a one-person parcel shop, and it is worth writing down because the opposite is being implied widely: PPWR reuse targets are not the next thing a parcel sender has to build. The duties that did reach small sellers on 12 August 2026 are the EPR side and the manufacturer side — see the German desk and the note on void fill.

You buy a pallet now and then: If you receive or send goods on pallets or in crates, you are in the population these targets count — but typically as the carrier's customer, inside a system the carrier or a pool operator already runs. That is not the same as a filing duty, and the FAQ's Euro Pallet example is a system without a system operator at all.
You ship wholesale or B2B in pooled packaging: Then the flows are yours. Everything in the stricter flows attaches to packaging moving inside one company, between linked companies, or to another company within one Member State — which is what a wholesale arrangement is. Ask the pool operator for the system's Annex VI position in writing, and keep the answer: a pool that does not meet Annex VI does not move the Article 27 duty off you.
Your contract manufacturer or 3PL does the pallets: Fix in writing who participates in which reuse system for the packaging you buy or supply. The Regulation's reuse rules attach to economic operators using the reusable packaging, and this site's recurring finding on the EPR side applies here too: the party who "handles logistics" is not automatically the party with the duty.
You are a final distributor with a small shop: Different target, and there are size carve-outs: FAQ, chapter XIII questions 14 and 15 list final distributors with a sales area under 100 m² as fully exempt from the beverage reuse target (Article 29(10)), and micro-enterprises making no more than 1,000 kg of packaging available in a Member State per year as fully exempt (Article 29(13)(a)). Those exemptions are written for the beverage target, not for transport packaging — do not read them across.

None of this is legal advice, and it is not a compliance programme. The practical version is shorter than the page: find out which reuse system your pallets and crates are in, and get that in writing, long before 2030.

What we could not establish

This page was assembled from one official news item, one official FAQ and one trade report. That is a thin base for a topic this size, and the gaps belong on the page rather than in a footnote.

We have not read the Regulation: EUR-Lex declined our requests when we tried (HTTP 202, three URL forms). So every article and paragraph number on this page — Article 11, Article 12(6), Article 27, Article 29(1)–(4), Article 29(10), Article 29(13)(a), Article 30(3), Article 62(1)(h), Annex VI — comes from the Commission or the trade report quoting it. Check each against EUR-Lex before relying on one.
The 2040 level: Press only. We could not find the 70% figure in any Commission document we could read. The Commission's 25 February 2026 news item states the 40% and stops there.
"Transport" versus "transport and sales": The Commission writes "transport and sales packaging"; the trade report writes "transport packaging". This may be loose phrasing on one side, or a difference in scope. We cannot tell which without the Article 29 text.
The delegated act on wrappings and straps: We have the Commission's announcement — adopted 25 February 2026, first application of a delegated act under the PPWR — and nothing of the act itself. We could not open the decision's own page, so we have no act number and no formal date of entry into force, and the exact scope of the exclusion is the Commission's summary, not the operative text.
The Commission's guidance document: The FAQ repeatedly refers to a Commission guidance document (including its point 25, on further exemptions). The Commission's packaging-waste page lists it as guidelines for economic actors and Member States, March 2026. We did not read it — the publication URL we could find returns 404 to us — and it may well settle some of the open points above.
The 2034 review: One FAQ question states as its premise that "the Commission will review the reuse targets in 2034". That is the question's framing — the Commission's answer discusses the exemption power and does not confirm the review or its date. We are not repeating it as a fact.
Delegated or implementing act under Article 11(2)?: The FAQ calls it a delegated act in chapter XIII question 1 and an implementing act in chapter X question 2 — the same article, two instrument types. One of the two is a slip; we cannot say which, and it matters for how the minimum rotations land.
How the percentages will be measured: Not yet knowable. The implementing act under Article 30(3), due by 30 June 2027, carries the rules on calculating achievement of the reuse targets, plus the treatment of "transport units". Until it exists, no one can compute their 40% — and no one should tell you otherwise.

Known traps

"Pallets are in scope, so my cartons must be too"

Backwards. Article 29(4)(d) exempts cardboard boxes — corrugated included — and the FAQ says the format list in Article 29(1) is exhaustive. The pallet is on the list; the box is not.

"Pallet packaging is exempt now"

Two formats are, and only from part of the requirement: wrapping and straps, from the 100% reuse rule for intra-company and single-Member-State flows, by delegated act of 25 February 2026. The pallet itself is not exempt, and the Commission's stated reason is to help operators hit the overall 40%.

"We return the pallets, so we're fine"

Article 27 asks you to participate in a reuse system meeting Annex VI, Part A, and to ensure it complies. Gating returns on a deposit is a return process, not necessarily a reuse system — and it is the trade report's point, not the FAQ's, that this is where businesses will need data rather than a delivery note.

"I'll switch to a pooling operator and that's my compliance"

Pooling is an option, not a legal requirement — the FAQ says a system operator is not required, and gives the Euro Pallet as a system without one. Choosing a pool does not by itself discharge Article 27: the system has to meet Annex VI.

"This is live: the PPWR applies since August 2026"

The Regulation does. The reuse targets are dated 1 January 2030 or 18 months after the entry into force of the calculation act under Article 30(3), due by 30 June 2027 — so the later date is not calculable yet. Reusable packaging under Article 11 does apply from 11 February 2025, but without the minimum number of rotations until the Article 11(2) act, due by 12 February 2027.

"Every pallet will have to be tracked in real time"

Not what the sources say. The trade report is explicit that no real-time tracking of every individual pallet is required, and the FAQ exempts open-loop systems without a system operator from rotation reporting and reuse labelling altogether. Tracking is one way to produce the evidence; it is not the obligation.

"We're a one-person business, so none of this applies"

Mostly right on the parcel side — cardboard boxes are exempt and the format list is not yours — but wrong the moment you ship palletised or pooled loads into wholesale flows, where the stricter tier sits. It depends on your flows, not your headcount.

Sources

Two official documents carry the weight here, and we say which part of each one a claim comes from rather than citing them as a lump.

European Commission, DG Environment — "Pallet wrapping and straps exempt from 100% reuse requirement under Packaging and Packaging Waste Regulation", 25 February 2026 Official. Read in full for this page. Source for: the delegated act adopted 25 February 2026 and the Commission's own description of it as the first application of a delegated act under the PPWR; the exclusion of wrapping and straps used to secure goods on pallets; the statement that the PPWR "had previously set a 100% reuse target for the two items when used within companies and between companies in the same Member State"; the disproportionate-adaptation-cost finding and the feasibility study; the public feedback window of 10 December 2025 to 9 January 2026; the 40% target from 1 January 2030 and the format list (pallets, foldable-plastic boxes, boxes, trays, plastic crates, IBCs, pails, drums, canisters, including pallet wrapping and straps); and the entry into force date of 11 February 2025
European Commission — PPWR Frequently Asked Questions, 2nd edition (KH-01-26-068-EN-N), August 2026 Official: DG ENV Unit B01. Read for this page, from the copy we mirror and describe here. Source for: chapter X question 2 on the reuse targets applying from 1 January 2030 or 18 months from entry into force of the implementing act under Article 30(3) due by 30 June 2027, and on Article 11 applying from 11 February 2025 with the rotations act due by 12 February 2027; chapter XIII question 1 on rotation reporting, the open-loop exemption in Annex VI Part A section 1(i), the Article 12(6) implementing act, and verification by market surveillance authorities under Article 62(1)(h); chapter XIII question 2 on open-loop systems, the Euro Pallet and the statement that a system operator is not a legal requirement; question 3 on the Article 27 duty to participate in a reuse system meeting Annex VI; question 4 on equal access and coverage; question 5 on EPR and reuse systems; question 6 for the cardboard-box exemption under Article 29(4)(d) and interlayers; question 7 for the Article 29(4)(c) food-and-feed carve-out; question 8 on wrappings and straps as two formats; question 9 for Article 29(1) being an exhaustive list; question 10 on "transport unit"; questions 14 and 15 for the beverage-target size exemptions in Article 29(10) and Article 29(13)(a); and question 16 for the Commission's delegated-act power to exempt operators or formats, and for the 2034 review appearing only in the question. Note its own disclaimer: it reflects the views only of its authors and is not binding law
European Commission, DG Environment — Packaging waste Official. Read for this page. Regulation (EU) 2025/40 "in force since 11 February 2025", application date 12 August 2026; the PPWD generally repealed on 12 August 2026; the list of derogations, including the decision exempting certain economic operators that use pallet wrappings and straps from the 100% reuse requirements of those formats; and the existence of the March 2026 guidelines and the August 2026 FAQ. Cited for the framework dates, not for the reuse figures
Regulation (EU) 2025/40 (PPWR) — EUR-Lex The governing text, and what both the FAQ and the trade report are summarising. We could not open it when writing this page — EUR-Lex declined our requests — so article and paragraph numbers here trace back to those sources quoting them. Where they disagree, this is what governs
Trans.INFO — "PPWR puts pallets under stricter reuse rules" (Agnieszka Kulikowska-Wielgus, 2 October 2026) Secondary, and the report that prompted this page. Read in full. Sourced on this page only where marked press: the 70% level from 1 January 2040 and its softer "expected to work towards" wording; the "related companies" limb of the stricter flows; the "functioning reuse system" reading, including packaging being prepared for its next use and the data on assets being used, returned, repaired and returned to service; the statement that no real-time tracking of every individual pallet is required; and the sentence that responsibility for operating shared reuse systems may be assigned to a third party. It cites no article numbers for any of it, and it is the same article that states the 100% framing, which the Commission's news item does confirm independently

One thing worth saying about the trade press here. The 2 October 2026 report is the only source we have seen that treats pallet reuse as an operational and data problem rather than a fee problem, and on that it reads better than most of the compliance-vendor material around it. It is still a trade article with no article numbers, one of its figures (70%) is unsupported by anything official we could read, and one of its limbs (related companies) has no Commission counterpart. We have used it, and we have labelled it.

Help us keep this page honest

What this page most needs is not more reading. It is two things from a business that actually runs pallets: the name of the reuse system your supplier or carrier says your packaging belongs to, and what they gave you in writing about it. If the answer is "you're covered", that is the sentence worth sending us, because it is what a thousand small sellers will be told between now and 2030. And if you have the delegated act of 25 February 2026 or the March 2026 guidelines, we would take the link — the act number alone would let us correct the section above.

Tell us on Discord Void fill and the minimisation duty The Commission's PPWR FAQ