Reuse obligations depend on the packaging format and transport flow. The general 40% target cannot be applied to an entire packaging portfolio. Check the specific rules for internal and domestic movements, grouped packaging, beverages and refill, together with relevant exemptions.
Reuse is a separate part of the PPWR
Recycling is not the only tool for a circular economy. The PPWR establishes separate requirements for reusable packaging, reuse systems and refill. For many companies, this requires a logistics and operational project as well as material decisions.
1. What does reusable packaging mean?
Reusable packaging must be designed and placed on the market with the intention of completing multiple trips or rotations. It must also satisfy the PPWR requirements concerning its functionality and the reuse system.
2. A 40% target for specified transport packaging
From 1 January 2030, economic operators using the specified transport packaging or sales packaging used for transporting products within the Union must ensure that at least 40% of the covered packaging in total is reusable within a reuse system. This target concerns Article 29(1), subject to exemptions and the separate rules for flows covered by paragraphs 2 and 3. It is not a single threshold for every packaging format or delivery route.
According to the Commission’s guidance, responsibility for the target lies with the user of the transport packaging: the operator placing the product in that packaging on the EU market, whether acting as a manufacturer, importer or distributor.
3. The 2040 objective: endeavour to reach 70%
For the same packaging group, operators must endeavour to reach at least 70% reusable packaging from 2040. It matters whether the legal wording imposes an obligation to ensure a result or an objective to endeavour to achieve it.
4. Movements between own sites and linked enterprises
For specified transport packaging moving between different sites of the same operator, or between that operator's sites and sites of linked or partner enterprises, the PPWR provides for reusable packaging within a reuse system from 2030. These stricter requirements must be read together with the relevant exemptions.
5. Deliveries to another operator in the same Member State
Article 29 also contains a specific rule for covered deliveries within the same Member State. The assessment must consider the transport route and business relationship, as well as the packaging format and any applicable exemption.
6. Exemptions for transport packaging
The obligations in Article 29(1)–(3) do not apply in certain defined cases. These include specified packaging for dangerous goods, individually designed packaging for large machinery and equipment, certain flexible packaging in direct contact with food or feed, and cardboard boxes. The reason for using an exemption should be documented.
A further relevant measure is Commission Delegated Decision (EU) 2026/429 concerning pallet wrappings and straps used to stabilise and protect products during transport. It provides an exemption from the 100% reuse requirements for those formats under Article 29(2) and (3). Assess the particular transport flow; this is not a general exemption for every form of transport packaging.
7. A 10% target for specified grouped packaging
From 2030, the PPWR requires at least 10% reusable packaging within a reuse system for grouped packaging in the form of boxes, excluding cardboard boxes. From 2040, operators must endeavour to reach 25%.
8. A 10% target for covered beverages in reusable packaging
From 2030, final distributors making the covered alcoholic and non-alcoholic beverages available to consumers must ensure that at least 10% of those products are supplied in reusable packaging within a reuse system. Check the product exclusions and operator exemptions before calculating the target. The objectives for 2040 are set separately.
9. Refill and reusable packaging are different concepts
Refill can involve filling a user's container again or using a refill station. Reuse generally involves packaging completing successive rotations in an organised system. The models require different arrangements for hygiene, logistics, identification and responsibility.
10. Large shops and space for refill
From 1 January 2030, final distributors with a sales area above 400 m² must endeavour to dedicate 10% of that area to refill stations for food and non-food products. This is an endeavour-based objective, not an unconditional requirement that every such shop has already installed that percentage of refill space.
11. A reuse system needs reliable data
A company should know how many packs are in circulation, where they are, how many rotations they complete, when they are withdrawn, how they are cleaned and what happens at the end of their service life.
12. Reuse does not remove recyclability requirements
Reusable packaging eventually becomes waste too. Its design should therefore balance durability, the number of rotations, cleanability, logistics and subsequent recycling.
13. How to start the company assessment
- Identify all transport and grouped packaging.
- Separate domestic, cross-border and intra-group flows.
- Review existing return loops.
- Calculate the share of reusable packaging.
- Determine rotation numbers and packaging losses.
- Assess washing, quality control and storage.
- Check and document exemptions.
- Develop a plan for 2030 and 2040.
The key principle
The reuse target depends on the format and the flow. Do not apply a single percentage to the entire packaging portfolio.
Frequently asked questions
Does the 40% target cover all packaging?
No. It concerns the specified transport packaging and sales packaging used for transport covered by Article 29, with the applicable exclusions and exemptions.
Is 40% sufficient for movements between our own sites?
No. Flows covered by Article 29(2) are subject to a 100% requirement, with the applicable exemptions, including those in Decision (EU) 2026/429. First establish whether the actual flow and packaging fall within that obligation.
Does reusable packaging also need to be recyclable?
Yes. Reuse does not remove requirements concerning the packaging's end of life.
Does every flexible packaging format fall under the reuse targets?
No. The Commission’s FAQ explains that Article 29(1) lists the covered formats exhaustively, including flexible versions of those formats. First identify the format and its use, then assess the applicable exemptions, including the specified cases of direct contact with food or feed.