Reusable transport packaging: the B2B targets the Commission has not costed

The one transport packaging format whose switch to full re-use was seriously studied got itself exempted. On February 25, 2026, the European Commission removed pallet wrappings and straps from the 100% re-use obligation of the Packaging and Packaging Waste Regulation (PPWR), citing disproportionate adaptation costs. Every other format, pallets, boxes, crates, drums, stays in scope, and the Commission has published no equivalent costing for any of them.

The obligations sit in Article 29 of Regulation (EU) 2025/40, in force since February 11, 2025 and applicable from August 12, 2026. They land in 2030, which sounds far away until you count the budget cycles it takes to change a packaging fleet, a pooling contract, and a counting system.

What Article 29 requires, deadline by deadline

From January 1, 2030, any economic operator using transport packaging in the EU, or sales packaging used for transporting products, including e-commerce shipments, must ensure that at least 40% of it is reusable packaging within a re-use system. The list of formats is explicit: pallets, foldable plastic boxes, boxes, trays, plastic crates, intermediate bulk containers (IBCs), pails, drums, and canisters of any size or material, including flexible formats and the wrap and straps that hold a loaded pallet together.

From 2040, the same operators must aim for 70%. The verb matters: the 2030 target is binding, while the 2040 one only obliges operators to try, "endeavour" being the regulation's own word.

A parallel target covers grouped packaging, the boxes (excluding cardboard) used to bundle products into a stock-keeping unit: 10% reusable by 2030, with a 25% goal for 2040.

Both targets are counted per calendar year. Micro-enterprises placing no more than 1,000 kg of packaging on a Member State's market in a year are exempt.

Between your EU sites, full re-use becomes the rule in 2030

The 40% figure is the headline, but it is the least demanding part of Article 29. Under Article 29(2), packaging moving between different sites of the same operator, or between an operator and a linked or partner enterprise as defined in the EU's SME Recommendation (2003/361/EC), must be entirely reusable from January 1, 2030. Article 29(3) applies the same 100% requirement to deliveries to any other economic operator within the same Member State.

Read together, the 40% target effectively governs only cross-border flows between independent companies. Everything intra-group and everything domestic is meant to run on reusable packaging.

The exemptions in Article 29(4) are therefore where the real scoping work happens: packaging for dangerous goods, custom-designed packaging for large machinery and equipment, flexible packaging in direct contact with food, and cardboard boxes. The last one carries the most consequences. A cardboard box on the same route as a plastic crate is simply out of scope.

Then there is the February 2026 decision. Delegated Decision (EU) 2026/429 exempts pallet wrappings and straps from the 100% requirements of paragraphs 2 and 3 only. They still count toward the overall 40% pool, where the regulation explicitly lets a format with a low re-use rate be offset by one with a high rate.

Pallets and crates: pooling has already done half the job

Article 27 requires every operator using reusable packaging to participate in one or more re-use systems meeting the conditions of Annex VI, covering governance, collection, and reconditioning, and allows that responsibility to be handed to a third party running a mutualized system. That is the legal description of what logistics has practiced for decades under the name of pooling.

The open exchange pool run by EPAL (the European Pallet Association) counts roughly 670 million Euro pallets and 20 million box pallets in circulation, produced and repaired by more than 1,700 licensed workshops. On the crate side, rental pools operate at comparable scale: Euro Pool System, one of the largest in fresh produce, states that its foldable trays last more than seven years on average and travel folded on the return leg.

Good to know: the two pooling models sit differently in your accounts. In an exchange pool you own the pallets and swap them one for one at each dock; in a rental pool the operator keeps ownership and bills per rotation. Both can qualify as a re-use system, provided the Annex VI conditions on collection and reconditioning are met.

The formats without an established pool, custom trays, straps on specialty flows, one-way IBCs in some chemical chains, are where 2030 will actually cost money. Across all formats, what is still missing is the evidence.

Counting rotations: the part nobody has tooled up for

Article 30 sets the proof. For each target separately, you must count, per calendar year, the equivalent units of each listed format used as reusable packaging within a re-use system, and the units used that were not. The precise methodology comes in an implementing act due by June 30, 2027, and the obligation to demonstrate compliance applies from January 1, 2030 or 18 months after that act enters into force, whichever is later.

Article 31 sets the audience. Operators report to their national authority within six months of year-end, the first reporting year is 2030, and Member States make the reports public. Your re-use rate will be readable by your customers and your competitors alike.

One more moving piece: packaging only counts as "reusable" if it meets the design conditions of Article 11, and the Commission must set a minimum number of rotations per format by February 12, 2027.

The practical question to ask now, the one I put to the logistics managers I work with: who in your company can say how many pallets a given site used last year, and how many were in a pool? So far the answer has been the same everywhere. The data exists, scattered across warehouse management systems, pooling contracts, and delivery notes, and nobody has ever had to add it up.

Between now and the 2027 calculation method, the useful work is an inventory. List your transport packaging flows by format and by route, intra-group, domestic, cross-border, mark what already runs through a pool, and flag the formats with no re-use channel at all. That inventory will tell you whether your 40% is already banked, or whether it gets negotiated with your carriers and packaging suppliers starting this year.

FAQ

Do the PPWR re-use targets apply to cardboard boxes?

No. Article 29(4) of Regulation (EU) 2025/40 excludes cardboard boxes from the re-use targets for transport packaging, along with packaging for dangerous goods, custom-designed packaging for large machinery, and flexible packaging in direct contact with food.

What counts as a re-use system under the PPWR?

A re-use system is the organizational, technical, or financial arrangement that ensures packaging is collected and used again, in a closed or open loop. It must meet the conditions of Annex VI of the regulation, covering governance, collection, and reconditioning. Operators may appoint a third party, such as a pooling provider, to run the system on their behalf.

Do pallets exchanged through a pool count toward the 40% target?

Yes, provided the pool meets the requirements of Annex VI, Part A of Regulation (EU) 2025/40. Both exchange pools, where each company owns and swaps pallets, and rental pools, where the pool operator retains ownership, can qualify as re-use systems.

When do companies have to start reporting their re-use rates?

The first reporting year is 2030, with the report due to the national competent authority within six months of year-end. The calculation methodology is expected in an implementing act by June 30, 2027, and the obligation to demonstrate compliance applies from January 1, 2030 or 18 months after that act enters into force, whichever is later.