Article 29(3) PPWR – re-use obligations for e-commerce and logistics. Do they apply to your company?

Key takeaways

• The obligations rest on “economic operators”, not only on producers. The definition in Article 3(12) covers, among others, distributors, final distributors and fulfilment service providers – typical roles in e-commerce and logistics. Consumers and end users remain outside that catalogue.
• One general rule and two derogations upwards. Article 29(1): at least 40% from 1 January 2030 for transport packaging (and for sales packaging used to transport products – the regulation expressly names e-commerce as well) in the EU; from 2040, an “endeavour” target of 70%. Paragraph 2 (movements within a company or a group) and paragraph 3 (supplies to another economic operator in the same member state) provide for reusable packaging only from 2030. What is left under the general 40% threshold is, in practice, mainly cross-border transport between independent companies.
• Watch out for a popular oversimplification. “40% from 2030” is the threshold of the cross-border regime (Article 29(1)). For domestic B2B trade (Article 29(3)) the requirement goes further – reusable packaging only – so for Polish e-commerce and logistics the subject is more urgent, not milder.
• Formats. The targets cover pallets, foldable plastic containers, boxes, trays, plastic crates, intermediate bulk containers (IBCs), pails, drums and canisters – of every size and every material – including flexible formats as well as pallet wraps and straps. Cardboard boxes are excluded from the re-use targets (Article 29(4)(d)), which does not mean that “PPWR does not apply to us”.
• It is the system that counts, not the crate on its own. Packaging counts towards the target only “within a re-use system”: reverse logistics, records, washing, the redemption rate. A sturdier box without a return loop is not yet compliance.

• The heaviest burden falls on the B2B layer, not on the parcel to the consumer. The Article 29 targets concern movements between economic operators and between sites (warehouse to hub, company to company) – precisely the part of the operation that e-commerce and 3PL most often assume “the producer will sort out”.

   

What Article 29(3) PPWR is, and why “it does not apply to me” usually does not hold

PPWR – Regulation (EU) 2025/40 of the European Parliament and of the Council – applies directly in every member state and has applied since 12 August 2026. Its Article 29 sets the re-use targets for transport packaging. One distinction matters most: the regulation addresses those targets to “economic operators that use transport packaging”, not to an abstract “producer”. If you are only starting out with the subject, we gather the basics of the whole regulation in our guide to PPWR for Polish companies. The mainstream of the PPWR debate equates the obligations with the packaging producer. It is a mental shortcut that can prove costly in e-commerce and logistics. Article 3(12) defines an economic operator broadly, and the roles it lists include distributors, final distributors and fulfilment service providers. In other words: a company that “merely” stores, picks and ships someone else’s goods is an economic operator within the meaning of the regulation too. Consumers, together with industrial and commercial end users, remain outside the catalogue – but a logistics operator or an online seller is neither of those. That is why the question in the title is not rhetorical. “Does it apply to your company?” is settled not at the level of a name or a sector, but at the level of two facts: whether you use transport packaging in the listed formats, and which loop it circulates in. Large, recognisable e-commerce, courier and 3PL brands carry these obligations in exactly the same way as smaller companies do, and in the same way as you probably do. We deliberately do not name particular market operators: the obligation follows from the role in the loop, not from the name over the door.

Three loops, three clocks: the 40% target and two full reusability regimes – which one is your company in

Article 29 does not set a single threshold. It sets a general rule and two derogations upwards, depending on between whom and where the packaging travels. The general rule (Article 29(1)). From 1 January 2030, at least 40% of transport packaging – and of sales packaging used to transport products, “including products distributed through e-commerce” – must be reusable packaging within a re-use system. From 1 January 2040 a 70% target appears, worded as an “endeavour” and therefore softer than the hard 40% threshold. Because the next two paragraphs provide only for reusable packaging in closed and domestic loops, what remains in the general 40% regime is, in practice, mainly cross-border transport between independent companies. Movements within a company or a group (Article 29(2)). When you move goods between your own sites, or between linked and partner enterprises in the EU, from 1 January 2030 that packaging must be reusable only. This is the “short”, controlled loop: you know both ends, so the legislator sets the bar highest here. Domestic movements to another economic operator (Article 29(3)). Here is the crux for Polish e-commerce and logistics: when transport packaging serves to deliver products to another economic operator in the same member state, from 1 January 2030 reusable packaging only must be used. For an operator handling domestic supply chains – a seller’s warehouse, a fulfilment centre, a transhipment hub, a shop, a collection point – this is most often the regime in play. In practice it means that single-use packaging in the listed formats is leaving domestic B2B trade: in those loops, single use in those formats stops being an option.

An illustrative scenario . A 3PL operator serves domestic e-commerce: it collects goods on load carriers from several sellers, consolidates them at a fulfilment centre and delivers them to hubs and collection points, all within one country. Pallets and containers circulating “economic operator to economic operator in the same country” fall under the full reusability regime (Article 29(3)). If the same operator carried part of the volume to a sister company’s warehouse abroad, that part would count towards the within-group regime (Article 29(2)). Exports to an independent distributor in another country count towards the 40%/70% target (Article 29(1)). One company, three compliance clocks at once.

“Economic operator” – are e-commerce, 3PL and couriers on the list

Article 3(12) lists as economic operators manufacturers, suppliers, importers, distributors, authorised representatives, final distributors and fulfilment service providers. The first word of that list is not accidental: the regulation speaks of a manufacturer, not of a “producer”. “Producer” belongs to the extended producer responsibility (EPR) regime and does not appear in the catalogue of economic operators in Article 3(12); that distinction is a frequent source of confusion when working out who is covered by Article 29. For the sector, a simple truth follows: the role of “intermediary in the loop” does not release anyone from the re-use obligations. A courier company, a fulfilment operator and an online shop are on that list even if they have never made a single item of packaging – and courier containers and the load carriers in which goods travel between sortation centres are subject to the same targets as the manufacturer’s crates. There is, however, a boundary worth understanding precisely, and it separates sound analysis from scaremongering. The full reusability regimes are defined in the provision itself as trade between economic operators: paragraph 2 concerns flows within a company and a group, and paragraph 3 concerns the delivery of products “to another economic operator” in the same member state. A consumer does not appear in the closed catalogue in Article 3(12), so a parcel to a private customer does not fall under those regimes. Neither does a professional end user appear there: a company that buys a product for its own industrial or professional use and does not make it available further in the form in which it was supplied (Article 3(23)). A delivery to such a recipient, although formally business to business, falls under the general 40% target in paragraph 1, not under the regime in paragraph 3. That general 40% target is broader – it expressly covers products distributed through e-commerce as well – but it applies to the listed formats, and cardboard boxes are excluded from the targets (paragraph 4(d)). The Commission’s first official interpretative guidance on the substantive provisions of PPWR appeared on 5 June 2026 (Commission Notice C(2026) 3702, published in the Official Journal of the EU as C/2026/3084 of 10 June 2026) and covers, among other things, the re-use targets; the finer points of classification are still worth settling cautiously and following further interpretations. One thing is certain: the heaviest burden falls on the B2B layer of your operation – the load carriers, pallets, containers and trays circulating between warehouses, fulfilment centres, hubs and partner companies. It is a paradox, because that is exactly the layer e-commerce most often treats as “invisible”, and it is where most of the obligation sits.

What actually falls under the obligation – formats, cardboard and exclusions

Before you calculate your percentage, you need to know what counts towards it. Article 29(1) covers transport packaging as well as sales packaging used to transport products, and lists the formats: pallets, foldable plastic containers, boxes, trays, plastic crates, intermediate bulk containers (IBCs), pails, drums and canisters – of every size and every material – including flexible formats as well as the wraps and straps that stabilise loads on pallets. This is the typical “circulating equipment” of the warehouse and of transport. The most important exception for e-commerce: cardboard boxes are excluded from the re-use targets (Article 29(4)(d)). A company that ships “in cardboard” readily concludes that “this does not concern us”. The conclusion is premature, for three reasons. First, the reusable formats you use in B2B trade anyway (pallets, containers, trays) are covered, whatever the product travels in on its way to the customer. Second, cardboard does not disappear from the regulation: it remains subject to the requirements on limiting empty space and packaging weight (Article 24, among others) and to the packaging waste reduction targets. Third, the direction of policy itself – a premium on the return loop – changes the economics of “cardboard” shipping over time. The cardboard exclusion is not immunity but a narrow exception for a single format. The remaining exclusions in Article 29(4): packaging for the transport of dangerous goods; packaging designed to individual order for the transport of oversized machinery, equipment and goods; and flexible formats in direct contact with food and feed. Separately, paragraph 13 exempts micro-enterprises from the targets, provided both conditions are met together in a given year: no more than 1,000 kg of packaging made available in the member state concerned, and micro-enterprise status under Recommendation 2003/361/EC (fewer than 10 persons, turnover or balance sheet total up to EUR 2 million). There is also the first delegated act under PPWR – Delegated Decision (EU) 2026/429, adopted on 25 February 2026 and in force since 26 May 2026 – which excluded pallet wraps and straps from the full reusability requirement (within-group and domestic B2B movements); they still count towards the 40% target. We unpack the mechanics of that act and forecast further exclusions separately: the first PPWR delegated act – analysis.

“Within a re-use system” – what a lawyer will not count

The five most important words in Article 29 are not the percentages but the phrase “within a re-use system”. Buying sturdier containers is not yet compliance with PPWR. Packaging counts towards the target only once a system works around it: reverse logistics, washing and inspection, records of circulation, an ownership model (an in-house pool or an operator) and compliance with the requirements of such a system, among them a minimum number of rotations, equal access for participants and reporting. From the perspective of a manufacturer of reusable packaging, the quiet hero of the whole of Article 29 is the redemption rate: whether the load carrier comes back to you. In e-commerce and logistics, where routes are often dispersed and endpoints numerous, it is closing the return loop – and not the purchase of equipment as such – that decides whether the declared “re-use percentage” matches reality at the loading bay. That is why the legislator placed the full reusability regimes where the loop is shortest and easiest to control (within a company, domestic movements): there the return can be enforced organisationally. We develop the same logic from the design side in our analysis of Article 29 PPWR for transport packaging. How does design answer a dispersed loop? As a manufacturer of reusable packaging, we design load carriers precisely around the three weak points of the e-commerce and 3PL network: protecting picked goods in transit (distribution containers with an integrated lid and openings for sealing), the cost of empty miles (stack-nest and collapsible designs – once emptied, a collapsible crate takes up as much as around 80% less space on the return leg; bekuplast public product data), and records of circulation (individual marking and RFID compatibility, without which the redemption rate cannot be measured).

Where to start – a plan for e-commerce and 3PL operations by 2030

There is less time to the first thresholds (2030) than the date suggests, because the change concerns physical infrastructure and reverse logistics, not paperwork alone. A sensible order of action:

1. Take stock of load carriers and loops. List your transport packaging (pallets, containers, trays, IBCs) and map the routes: within the company, domestic B2B, cross-border.
2. Classify loops and formats. Assign each loop to a regime (domestic or within-group closed loop versus the 40/70% cross-border target) and mark what is excluded (cardboard; wraps and straps exempted by Decision (EU) 2026/429; dangerous goods).
3. Pilot on one route. Choose one controllable domestic loop and test reusable packaging for e-commerce in practice: the load carriers, the return logistics and the measurement of the redemption rate.
4. A model decision. Your own pool of load carriers or a pooling operator; records, washing, reverse logistics. This is a genuine TCO choice (own capital versus operating cost), not a matter of fashion. Let us be honest about it: pooling is market context and an option on the customer’s side, not a service we sell here – bekuplast is not a pooling operator.
5. Specification for the cycles. Selecting a load carrier for repeated circulation (durability, foldability, identification), together with a manufacturer of reusable packaging.

To be honest: this is an investment, not an automatic saving. Moving to reusable load carriers is an outlay (buying the fleet, washing, reverse logistics, records) that pays back over many cycles – but the fleet is not “bought once and for all”: load carriers wear out, some are lost or damaged (breakage), so a recurring fleet replacement cost comes on top, a real component of the calculation rather than a one-off purchase. The result of such a calculation is directional: it shows the break-even point (“reusable load carriers cheaper from around year X”), not a hard payback in months or an ROI in per cent, because it depends on rotation, the redemption rate and the actual routes. We do not quote a single “magic” number of cycles to the profitability threshold, because it depends on the specific network; anyone promising a universal threshold is selling a simplification. We show the directional break-even calculation, with the assumptions stated openly, in the PPWR cost calculator; it is a result for budget planning, and it may come out in favour of either path. We describe the full methodology of the formulas in a separate article on the TCO calculator. If you would first like to see where your company stands, start with the PPWR readiness audit, and you will find further analyses and tools in the PPWR Knowledge Centre. For implementation details for your operation, see the sector page for e-commerce, 3PL and fulfilment.

FAQ

Does Article 29(3) PPWR apply to e-commerce, 3PL and courier companies?

Yes, if they are an “economic operator” using transport packaging in the listed formats. The definition in Article 3(12) covers distributors, final distributors and fulfilment service providers, so the role of intermediary in the loop does not release anyone from the re-use obligations.

What is the difference between Article 29(1), (2) and (3)?

Paragraph 1 is the general rule: at least 40% from 2030 (and an “endeavour” target of 70% from 2040) for transport packaging in the EU, expressly including e-commerce. Paragraphs 2 and 3 are derogations upwards: from 2030, reusable packaging only for movements within a company or a group and for supplies to another economic operator in the same member state. What is left under the general 40% threshold is, in practice, mainly cross-border transport between independent companies.

When do the re-use targets in Article 29 start to apply?

PPWR has applied since 12 August 2026, but the re-use thresholds start to apply on 1 January 2030, and the directional 70% target on 1 January 2040. The Commission is to adopt the methodology for calculating the targets in implementing acts by 30 June 2027 (Article 30(3)), and the obligation to demonstrate that the targets have been met applies from 1 January 2030 or 18 months after those acts enter into force, whichever date is later (Article 30(4)).

Are cardboard boxes in e-commerce covered by the Article 29 targets?

Cardboard boxes are excluded from the re-use targets (Article 29(4)). That does not mean PPWR leaves e-commerce alone: the reusable formats used in B2B trade (pallets, containers, trays) are covered, and cardboard itself is subject to other provisions, among them the limit on empty space (Article 24) and the waste reduction targets.

Does a parcel to a consumer fall under the Article 29 targets?

The full reusability regimes (paragraphs 2 and 3) concern, by the very wording of the provision, trade between economic operators, and the catalogue in Article 3(12) contains neither a consumer nor a professional end user – so a parcel to a private customer does not fall under those regimes, and neither does a delivery to a company buying goods for its own use. The general 40% target (paragraph 1) expressly covers e-commerce as well, but in the listed formats, and cardboard boxes are excluded (paragraph 4(d)). The heaviest burden therefore falls on the B2B transport layer.

Are there exemptions for small companies?

Yes. Article 29(13) exempts from the targets operators that in a given calendar year made available no more than 1,000 kg of packaging in the member state concerned and are a micro-enterprise under Recommendation 2003/361/EC (fewer than 10 persons, turnover or balance sheet total up to EUR 2 million) – both conditions together.