Series PPWR
PPWR 08 – Do I Need to Switch to Reusable Packaging?
2026.08.18 - 18:06
Reuse targets, refill and what will change for companies by 2030
● PPWR does not require all packaging to become reusable. ● Article 29 sets targeted reuse obligations for specific packaging categories. ● 2030 targets are binding; the 2040 figures are formulated as objectives operators “shall endeavour” to reach, and don’t carry the same legal force - they shouldn’t be presented as equivalent. ● A durable package isn’t enough - Article 29 relies on the existence of a system for reuse. ● Some transport flows carry a 100% requirement, but that doesn’t mean all transport packaging has to be 100% reusable. ● Pallet wrapping and straps received a specific 2026 derogation from the 100% sub-target - not a full exemption from reuse obligations. ● Reverse logistics, washing, inspection and loss rates can matter as much as the packaging itself. ● Companies should map their packaging flows now, before investing.
A plastics converter receives a request from a customer:
“We need a reusable version of this crate. Because of PPWR.”
The solution seems simple. The converter increases the wall thickness, changes the ribs and perhaps modifies the material. The packaging becomes more robust and can withstand many use cycles.
Is the problem solved?
Not necessarily.
Who brings it back? Who owns it? Who washes it? Who inspects it? Who removes damaged units from circulation? And what happens if part of the packaging never comes back?
This is where one of the important differences between reuse as an idea and reuse under PPWR becomes clear.
A package does not become reusable simply because we make it thicker. There must also be a system that brings it back into circulation.
Is it enough for the packaging to be thicker?
No. Physical robustness is necessary, but it is not sufficient.
Is it enough to print “reusable” on the product?
No. A commercial claim does not turn packaging into a functioning reuse system.
Does it matter whether the packaging is actually reused in practice?
Yes.
And this brings us to the central distinction of this article.
A system for reuse is the mechanism that actually makes that object circulate more than once.
In practice, the flow may look like this:
use → return → sorting → washing → inspection → refill or redistribution → use again
This is not an official PPWR flow imposed step by step for every reuse system, but it reflects the practical operating logic of reuse.
For companies, the distinction is essential.
You may manufacture a crate capable of surviving 100 uses. If it never returns after the first delivery, you have produced a highly durable product. But that alone does not create a reuse system.
A returnable beverage bottle collected, washed and refilled by the operator functions within a reuse system.
A customer bringing their own cup or container and asking for it to be filled follows a different logic: refill.
PPWR treats these situations separately.
The percentage-based reuse targets under Article 29 should not be confused with specific refill and takeaway packaging obligations set out elsewhere in the Regulation.
Article 29 differentiates between categories and flows.
For industry, the most important areas are transport packaging, certain specific transport flows, grouped packaging and certain beverage sales packaging.
For 2040, the figure is 70%, but the legal distinction matters: operators must endeavour to reach that level. It should not be presented as an obligation formulated in the same way as the binding 2030 target.
Depending on the exact format and use, this area may include:
These formats do not all receive exactly the same treatment. The format and the flow in which it is used need to be assessed together.
This can quickly lead to the conclusion:
“From 2030, all transport packaging must be reusable.”
No.
The 100% requirement applies to certain flows defined by the Regulation, mainly movements between sites of the same operator or linked/partner enterprises, and certain transport flows between economic operators within the same Member State.
So before asking whether a pallet, crate or other transport package must become reusable, the first question is:
Which flow does it move through?
The original Article 29 architecture exposed pallet wrapping and straps used for stabilisation and protection to the specific 100% requirement in certain transport flows.
Through Commission Delegated Decision (EU) 2026/429 of 25 February 2026, the European Commission exempted operators using these formats from the specific 100% requirements applicable to those flows.
But be careful:
This is not a complete exemption from reuse obligations.
Pallet wrapping and straps remain relevant to the general reuse target applicable to transport packaging.
In other words:
exemption from the specific 100% requirement does not mean exemption from PPWR.
For 2040, operators must endeavour to reach 25%.
The distinction between the binding 2030 obligation and the 2040 objective must also be preserved here.
The treatment of cardboard should be assessed exactly against the category covered by Article 29. It is not correct to extrapolate a specific exclusion and conclude that every cardboard or fibre transport package is automatically outside the reuse requirements.
There is also an important connection with PPWR 07.
Article 25 may restrict certain single-use grouped packaging formats. Article 29 separately introduces reuse targets.
These are two different mechanisms.
For 2040, operators must endeavour to reach 40%.
The Regulation also provides exclusions for certain beverage categories, including certain wine products, spirit drinks, milk and dairy products, and certain beverages requiring specific packaging conditions.
This is why the 10% rule should not be simplified into:
“10% of all beverages must be sold in reusable packaging.”
The exact product category and applicable conditions need to be checked.
The automotive industry has used returnable component boxes for decades. Other sectors already use reusable pallets, industrial crates, trays, IBCs and drums circulating repeatedly between the same operators.
Here, PPWR meets a mature industrial practice.
For part of industry, PPWR does not invent reuse. It turns an established logistics practice into a compliance element.
The difference is that reuse needs to be measurable, documented and reported where it falls under a legal target.
For companies that already operate well-organised closed-loop systems, the starting point may therefore be much stronger than it first appears.
It may mean different business.
Demand may grow for:
But as the opportunity changes, the technical specification also changes.
The discussion is no longer only about unit cost, stiffness and appearance.
Impact resistance, dimensional stability, chemical resistance, performance under repeated washing, UV resistance and closure durability may become increasingly important.
The design must take into account the expected service life of the product.
Relevant factors may include:
For the converter, this is where the project truly changes: not only the thickness of the part, but the logic according to which the part is designed.
Reusable packaging may legitimately be heavier than its single-use equivalent.
The reason is simple: its function is no longer to survive one use, but multiple rotations.
The “minimum necessary” therefore has to be assessed against the actual function of the packaging.
For reusable packaging, durability is part of that function.
The fact that packaging is reusable does not automatically remove recycled-content obligations where they apply to the relevant packaging category.
Reuse and recycled content are separate requirements that need to be assessed separately.
Reusable packaging will eventually reach the end of its life.
Durability does not remove the question:
What happens to it then?
A very durable package that is difficult to recycle may eventually create exactly the recyclability problem discussed in PPWR 04.
In certain cases, moving to a genuine reuse system may provide an alternative.
But the solution is not to take the old single-use package, make it slightly thicker and call it “reusable”.
A HoReCa cup, a food container or another format can work as a reusable solution only if there is a system behind the object capable of actually bringing it back into circulation.
These obligations must be kept separate from the percentage-based targets under Article 29 and from the restrictions on certain single-use packaging discussed in PPWR 07.
They are different mechanisms and should not be merged into one general rule about “reuse”.
But then it has to come back.
In a real system, this may mean:
return → storage → sorting → washing → inspection → redistribution.
And every step has a cost.
For this reason, reuse is not only a problem for the packaging producer.
It is a problem for the entire chain.
A company puts 100,000 reusable crates into circulation.
If a significant share disappears during every rotation, the company must keep manufacturing new units simply to maintain the system.
Costs increase. Material consumption increases. And the environmental advantage of reuse may decrease.
This is why, in a reuse system, the question is not only:
How many packages do we have?
It is also:
How many actually come back?
Reusable food-contact packaging must remain safe after repeated exposure to washing, detergents, temperature cycles and physical wear.
Scratching, surface degradation and changes in material properties may become relevant.
PPWR does not establish one universal washing protocol for all reusable packaging.
Food safety needs to be assessed in parallel under the specific applicable legislation.
QR codes, RFID, serial numbers and other identification technologies may be extremely useful in a reuse system.
They can support rotation tracking, inventory management, loss control, inspection and documentation.
But PPWR should not be interpreted as imposing a general obligation to use RFID or any specific technology.
Technology is the tool.
The system is the problem that needs to be solved.
Reuse can reduce the amount of packaging material consumed per use.
But it may also require:
In some applications, the economics may be very attractive.
In others, much more difficult.
Reuse therefore needs to be assessed as an economic system, not merely as a packaging project.
Performance depends on the actual number of rotations, return distance, energy and water used for washing, loss rate, packaging weight and end-of-life performance.
There is no universal number of cycles after which every reusable package automatically becomes environmentally preferable to a single-use equivalent.
It depends on the system.
WHAT I CAN TEST NOW
WHAT I SHOULD MONITOR
WHAT I WOULD NOT DO YET
False.
“Reusable means thicker.”
False.
“All transport packaging must be 100% reusable.”
False. The 100% requirement applies only to specific flows.
“Stretch film is completely exempt from reuse obligations.”
False. The 2026 derogation concerns the specific 100% requirement, not the entire reuse framework.
“The 2040 targets are legally identical to the 2030 targets.”
False. The legal wording is different.
“Reusable packaging no longer needs to be recyclable.”
False.
“Reuse automatically removes recycled-content obligations.”
False.
“If I have manufactured the container, I have solved the reuse system.”
False. The container is only one part of the solution.
“RFID is mandatory under PPWR.”
False.
“Reuse is always cheaper and better for the environment.”
False as a general rule. The result depends on the specific system.
Can it be recycled?
PPWR 05:
How much recycled material must it contain?
PPWR 06:
Am I using more packaging than necessary?
PPWR 07:
Can I still use this format for this application?
PPWR 08 adds:
Does part of this packaging flow need to move into a reuse system?
And with this question, the unit of analysis changes.
We are no longer analysing only the package.
We are analysing the package together with its entire circulation system.
“How do I make reusable packaging?”
The first question is:
“Do I actually have a reuse obligation for this specific flow?”
If the answer is yes, the next question is not only:
“What packaging do I manufacture?”
It is:
“How do I bring it back?”
That is probably the most important change in perspective.
Reuse is not only a packaging decision.
It is a packaging, logistics and operations decision taken together.
The PPWR series continues to develop around practical questions received from industry. If you have a packaging flow and are unsure how it should be assessed under Article 29, write to us.
#Plastinfo #PPWR #Packaging #ReusablePackaging #ReuseTargets #PackagingIndustry #PlasticsIndustry #CircularEconomy #EURegulation #HoReCa #TransportPackaging #SustainablePackaging
“We need a reusable version of this crate. Because of PPWR.”
The solution seems simple. The converter increases the wall thickness, changes the ribs and perhaps modifies the material. The packaging becomes more robust and can withstand many use cycles.
Is the problem solved?
Not necessarily.
Who brings it back? Who owns it? Who washes it? Who inspects it? Who removes damaged units from circulation? And what happens if part of the packaging never comes back?
This is where one of the important differences between reuse as an idea and reuse under PPWR becomes clear.
A package does not become reusable simply because we make it thicker. There must also be a system that brings it back into circulation.
Article 11 – what does “reusable packaging” actually mean?
Reusable packaging is conceived and designed to accomplish, during its life cycle, multiple trips or rotations, by being refilled or reused for the same purpose for which it was originally conceived. At the same time, it must be capable of withstanding the operations required for repeated use.Is it enough for the packaging to be thicker?
No. Physical robustness is necessary, but it is not sufficient.
Is it enough to print “reusable” on the product?
No. A commercial claim does not turn packaging into a functioning reuse system.
Does it matter whether the packaging is actually reused in practice?
Yes.
And this brings us to the central distinction of this article.
Reusable packaging versus a system for reuse
Reusable packaging is the object.A system for reuse is the mechanism that actually makes that object circulate more than once.
In practice, the flow may look like this:
use → return → sorting → washing → inspection → refill or redistribution → use again
This is not an official PPWR flow imposed step by step for every reuse system, but it reflects the practical operating logic of reuse.
For companies, the distinction is essential.
You may manufacture a crate capable of surviving 100 uses. If it never returns after the first delivery, you have produced a highly durable product. But that alone does not create a reuse system.
Reuse versus refill
The two concepts are related, but they are not identical.A returnable beverage bottle collected, washed and refilled by the operator functions within a reuse system.
A customer bringing their own cup or container and asking for it to be filled follows a different logic: refill.
PPWR treats these situations separately.
The percentage-based reuse targets under Article 29 should not be confused with specific refill and takeaway packaging obligations set out elsewhere in the Regulation.
Article 29 – where do the reuse targets apply?
PPWR does not establish one single reuse target for all packaging.Article 29 differentiates between categories and flows.
For industry, the most important areas are transport packaging, certain specific transport flows, grouped packaging and certain beverage sales packaging.
Transport packaging
For relevant transport packaging, the 2030 target is at least 40% reusable packaging made available within a system for reuse.For 2040, the figure is 70%, but the legal distinction matters: operators must endeavour to reach that level. It should not be presented as an obligation formulated in the same way as the binding 2030 target.
Depending on the exact format and use, this area may include:
- pallets;
- reusable crates and boxes;
- transport trays;
- IBCs;
- drums;
- pails and industrial containers;
- certain transport films;
- straps and other stabilisation elements.
These formats do not all receive exactly the same treatment. The format and the flow in which it is used need to be assessed together.
So where does the 100% rule come from?
One PPWR provision that can easily be misunderstood is the 100% reuse requirement for certain transport flows.This can quickly lead to the conclusion:
“From 2030, all transport packaging must be reusable.”
No.
The 100% requirement applies to certain flows defined by the Regulation, mainly movements between sites of the same operator or linked/partner enterprises, and certain transport flows between economic operators within the same Member State.
So before asking whether a pallet, crate or other transport package must become reusable, the first question is:
Which flow does it move through?
Pallet wrapping and straps – a very concrete example
This is a good example of why relying in 2026 on a PPWR summary written in 2025 can be risky.The original Article 29 architecture exposed pallet wrapping and straps used for stabilisation and protection to the specific 100% requirement in certain transport flows.
Through Commission Delegated Decision (EU) 2026/429 of 25 February 2026, the European Commission exempted operators using these formats from the specific 100% requirements applicable to those flows.
But be careful:
This is not a complete exemption from reuse obligations.
Pallet wrapping and straps remain relevant to the general reuse target applicable to transport packaging.
In other words:
exemption from the specific 100% requirement does not mean exemption from PPWR.
Grouped packaging
For the relevant grouped-packaging category, the binding target for 2030 is 10%.For 2040, operators must endeavour to reach 25%.
The distinction between the binding 2030 obligation and the 2040 objective must also be preserved here.
The treatment of cardboard should be assessed exactly against the category covered by Article 29. It is not correct to extrapolate a specific exclusion and conclude that every cardboard or fibre transport package is automatically outside the reuse requirements.
There is also an important connection with PPWR 07.
Article 25 may restrict certain single-use grouped packaging formats. Article 29 separately introduces reuse targets.
These are two different mechanisms.
Beverage sales packaging
For the relevant category of beverage sales packaging, the binding 2030 target is 10%.For 2040, operators must endeavour to reach 40%.
The Regulation also provides exclusions for certain beverage categories, including certain wine products, spirit drinks, milk and dairy products, and certain beverages requiring specific packaging conditions.
This is why the 10% rule should not be simplified into:
“10% of all beverages must be sold in reusable packaging.”
The exact product category and applicable conditions need to be checked.
Reuse in closed industrial loops
For part of industry, reuse does not begin with PPWR.The automotive industry has used returnable component boxes for decades. Other sectors already use reusable pallets, industrial crates, trays, IBCs and drums circulating repeatedly between the same operators.
Here, PPWR meets a mature industrial practice.
For part of industry, PPWR does not invent reuse. It turns an established logistics practice into a compliance element.
The difference is that reuse needs to be measurable, documented and reported where it falls under a legal target.
For companies that already operate well-organised closed-loop systems, the starting point may therefore be much stronger than it first appears.
Opportunity or risk for plastics converters?
Reuse does not automatically mean less business for the plastics industry.It may mean different business.
Demand may grow for:
- high-strength crates;
- reusable pallets;
- long-life containers;
- industrial boxes;
- reusable food containers;
- refill-system components;
- packaging compatible with identification and tracking systems.
But as the opportunity changes, the technical specification also changes.
The discussion is no longer only about unit cost, stiffness and appearance.
Impact resistance, dimensional stability, chemical resistance, performance under repeated washing, UV resistance and closure durability may become increasingly important.
Design for reuse
Reusable packaging is not simply single-use packaging that is used several times.The design must take into account the expected service life of the product.
Relevant factors may include:
- structural durability;
- wall thickness in relation to expected cycles;
- resistance to washing and cleaning agents;
- impact resistance under repeated handling;
- closure-system durability;
- stacking stability;
- dimensional stability;
- durability of markings and labels.
For the converter, this is where the project truly changes: not only the thickness of the part, but the logic according to which the part is designed.
Reuse versus minimisation
The connection with PPWR 06 is direct.Reusable packaging may legitimately be heavier than its single-use equivalent.
The reason is simple: its function is no longer to survive one use, but multiple rotations.
The “minimum necessary” therefore has to be assessed against the actual function of the packaging.
For reusable packaging, durability is part of that function.
Reuse versus recycled content
The link with PPWR 05 is equally important.The fact that packaging is reusable does not automatically remove recycled-content obligations where they apply to the relevant packaging category.
Reuse and recycled content are separate requirements that need to be assessed separately.
Reuse versus recyclability
And PPWR 04 remains relevant.Reusable packaging will eventually reach the end of its life.
Durability does not remove the question:
What happens to it then?
A very durable package that is difficult to recycle may eventually create exactly the recyclability problem discussed in PPWR 04.
Reuse versus Annex V restrictions
PPWR 07 examined the formats and applications that will face restrictions from 2030.In certain cases, moving to a genuine reuse system may provide an alternative.
But the solution is not to take the old single-use package, make it slightly thicker and call it “reusable”.
A HoReCa cup, a food container or another format can work as a reusable solution only if there is a system behind the object capable of actually bringing it back into circulation.
HoReCa – a separate regime
PPWR also contains specific requirements for the HoReCa sector concerning customer-owned containers and the provision of reusable alternatives for takeaway products.These obligations must be kept separate from the percentage-based targets under Article 29 and from the restrictions on certain single-use packaging discussed in PPWR 07.
They are different mechanisms and should not be merged into one general rule about “reuse”.
The less visible part: reverse logistics
Reusable packaging leaves together with the product.But then it has to come back.
In a real system, this may mean:
return → storage → sorting → washing → inspection → redistribution.
And every step has a cost.
- additional space for returned packaging waiting to be processed;
- transport for return flows;
- inventory permanently “in the field”;
- working capital tied up in circulating packaging;
- lost or damaged units;
- uncertainty around actual return rates.
For this reason, reuse is not only a problem for the packaging producer.
It is a problem for the entire chain.
How much packaging actually comes back?
Consider a purely operational example, not a PPWR formula.A company puts 100,000 reusable crates into circulation.
If a significant share disappears during every rotation, the company must keep manufacturing new units simply to maintain the system.
Costs increase. Material consumption increases. And the environmental advantage of reuse may decrease.
This is why, in a reuse system, the question is not only:
How many packages do we have?
It is also:
How many actually come back?
Washing and food contact
PPWR does not replace European food-contact materials legislation or hygiene rules.Reusable food-contact packaging must remain safe after repeated exposure to washing, detergents, temperature cycles and physical wear.
Scratching, surface degradation and changes in material properties may become relevant.
PPWR does not establish one universal washing protocol for all reusable packaging.
Food safety needs to be assessed in parallel under the specific applicable legislation.
Do I need RFID on every package?
No.QR codes, RFID, serial numbers and other identification technologies may be extremely useful in a reuse system.
They can support rotation tracking, inventory management, loss control, inspection and documentation.
But PPWR should not be interpreted as imposing a general obligation to use RFID or any specific technology.
Technology is the tool.
The system is the problem that needs to be solved.
Does reusable mean cheaper?
Not automatically.Reuse can reduce the amount of packaging material consumed per use.
But it may also require:
- a higher unit cost;
- new moulds or equipment;
- reverse logistics;
- washing;
- storage;
- tracking;
- inspection;
- replacement of lost packaging.
In some applications, the economics may be very attractive.
In others, much more difficult.
Reuse therefore needs to be assessed as an economic system, not merely as a packaging project.
And is it always better for the environment?
Again, the answer cannot automatically be “yes”.Performance depends on the actual number of rotations, return distance, energy and water used for washing, loss rate, packaging weight and end-of-life performance.
There is no universal number of cycles after which every reusable package automatically becomes environmentally preferable to a single-use equivalent.
It depends on the system.
What should I ask my customer as a converter?
Before redesigning a product, several simple questions are worth asking:- Is the packaging intended for genuine reuse, or does the customer simply want a more robust package?
- How many rotations are realistically expected?
- How will the packaging return into the system?
- Who owns it?
- Who washes it?
- Who inspects it?
- Who decides when it must be removed from use?
- Who bears the cost of losses?
- What temperatures and substances will it be exposed to?
- Is it intended for food contact?
- Which PPWR obligation or target is the customer actually trying to meet?
- Is there already a reuse system, or are we currently designing only the packaging?
What can I do now?
WHAT I CAN DO NOW- Map the packaging portfolio against the relevant Article 29 categories.
- Identify flows where reuse already exists.
- Identify flows that may fall under the specific 100% requirements.
- Estimate the current share of reusable packaging.
- Map existing reverse logistics.
- Analyse current loss rates.
- Identify available washing and reconditioning capacity.
WHAT I CAN TEST NOW
- Reusable packaging pilot projects.
- Closed-loop flows.
- Return systems.
- Pooling models.
- Tracking systems.
- Validation of washing processes.
- Actual customer participation in the system.
WHAT I SHOULD MONITOR
- The official calculation methodology for Article 29 targets.
- Any additional Commission derogations.
- Implementation details for HoReCa obligations.
- The exact treatment of exemptions applicable to certain operators and categories.
- European and national guidance on reporting.
WHAT I WOULD NOT DO YET
- I would not automatically convert every single-use package into a reusable one.
- I would not assume that “thicker” automatically means “reusable”.
- I would not build a reuse system without solving reverse logistics.
- I would not assume that every transport flow is subject to a 100% requirement.
- I would not treat the 2040 figures as legally identical to the binding 2030 targets.
- I would not make major investments before confirming whether the specific flow actually falls within Article 29.
Some common misunderstandings
“PPWR requires all packaging to become reusable.”False.
“Reusable means thicker.”
False.
“All transport packaging must be 100% reusable.”
False. The 100% requirement applies only to specific flows.
“Stretch film is completely exempt from reuse obligations.”
False. The 2026 derogation concerns the specific 100% requirement, not the entire reuse framework.
“The 2040 targets are legally identical to the 2030 targets.”
False. The legal wording is different.
“Reusable packaging no longer needs to be recyclable.”
False.
“Reuse automatically removes recycled-content obligations.”
False.
“If I have manufactured the container, I have solved the reuse system.”
False. The container is only one part of the solution.
“RFID is mandatory under PPWR.”
False.
“Reuse is always cheaper and better for the environment.”
False as a general rule. The result depends on the specific system.
From PPWR 04 to PPWR 08
PPWR 04 asked:Can it be recycled?
PPWR 05:
How much recycled material must it contain?
PPWR 06:
Am I using more packaging than necessary?
PPWR 07:
Can I still use this format for this application?
PPWR 08 adds:
Does part of this packaging flow need to move into a reuse system?
And with this question, the unit of analysis changes.
We are no longer analysing only the package.
We are analysing the package together with its entire circulation system.
The real question
The first question is not:“How do I make reusable packaging?”
The first question is:
“Do I actually have a reuse obligation for this specific flow?”
If the answer is yes, the next question is not only:
“What packaging do I manufacture?”
It is:
“How do I bring it back?”
That is probably the most important change in perspective.
Reuse is not only a packaging decision.
It is a packaging, logistics and operations decision taken together.
The PPWR series continues to develop around practical questions received from industry. If you have a packaging flow and are unsure how it should be assessed under Article 29, write to us.
OFFICIAL SOURCES
- Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste – in particular Articles 11, 29, 32 and 33 and the relevant provisions on systems for reuse.
- Commission Delegated Decision (EU) 2026/429 of 25 February 2026 concerning the derogation applicable to certain economic operators using pallet wrappings and straps.
- European Commission – Guidance document for Regulation (EU) 2025/40, C(2026) 3702.
CONTEXT SOURCES
- European Commission – Packaging and Packaging Waste Regulation (PPWR).
#Plastinfo #PPWR #Packaging #ReusablePackaging #ReuseTargets #PackagingIndustry #PlasticsIndustry #CircularEconomy #EURegulation #HoReCa #TransportPackaging #SustainablePackaging