Article 29 PPWR: reusable transport packaging – an analysis for manufacturers and distributors

Key takeaways

• Article 29 PPWR sets re-use targets for transport packaging (and for sales packaging used to transport products). The general rule (Article 29(1)): at least 40% from 1 January 2030, and from 2040 an endeavour target of 70% (“shall endeavour”) – counted as the combined share of packaging “within a re-use system”. In practice the 40/70% regime covers mainly cross-border trade between independent companies (and, for example, shipments to consumers), because the stricter paragraphs 2 and 3 take over the rest.
• In controlled loops, from 1 January 2030, packaging has to be fit for re-use within a re-use system in its entirety: in circulation inside a group, that is between an operator’s own sites and with linked and partner enterprises (Article 29(2)), and on supplies to another economic operator in the same Member State (Article 29(3)). For domestic B2B this is the stricter regime, not the lighter one. A point of terminology: the provision does not require the loop to be closed. It requires a re-use system, and under Annex VI such a system may run as a closed loop system (with no change in the ownership of the packaging) or as an open loop system (with a change of owner).
• The obligation applies to manufacturers and distributors alike, including 3PL, wholesale and e-commerce (Article 29(3) read together with Article 3(12)).
• The formats named in the provision are pallets, foldable plastic containers, boxes, trays, plastic crates, intermediate bulk containers (IBCs), pails, drums and canisters, of every size and made of any material – together with wraps (“pallet packaging”) and straps. The first delegated act under PPWR, Delegated Decision (EU) 2026/429 adopted on 25 February 2026, excludes wraps and straps from the re-use requirement in controlled loops (paragraphs 2 and 3); the 40% target still covers them in Article 29(1) applications.
• The hardest part is not the percentage itself but a working re-use system: a container designed for cycles, washing and folding, return logistics, the redemption rate and the replacement of a worn fleet. This is an investment, not an automatic saving, and the calculation is directional (it shows roughly from which year RTP becomes cheaper than single-use packaging), not a payback down to the month or an ROI in per cent.

What Article 29 PPWR is, and whom it covers

PPWR – Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste – entered into force on 11 February 2025 and has applied since 12 August 2026. As a regulation it binds directly in every Member State, with no national transposition. If you are only just starting with the subject, you will find an overview of the whole regulation in our introductory article.

Article 29 is the part of the regulation that sets re-use targets for transport packaging, that is for packaging used to move and group goods in trade between economic operators within the meaning of Article 3(12). This is not a provision about the sales unit that reaches the consumer. It is a provision about what your products travel in between the warehouse, the plant, the distribution centre and the B2B customer.

And here the first misunderstanding appears. The mainstream of the PPWR debate writes about “the producer’s obligations”. Article 29, however, covers two roles at once: the manufacturer and the distributor. A company that thinks “we only carry or resell goods, so this does not concern us” is usually wrong – the re-use obligations reach 3PL, e-commerce and wholesale as well. In this article we look at Article 29 from the perspective of a manufacturer that designs and makes these containers, rather than one that only interprets the provision.

Thresholds and dates: 40%, 70% and the closed loop – what Article 29 actually sets

Article 29 sorts transport packaging by who hands it to whom, and sets a different target for each case. Three paragraphs, three regimes, easily confused.

Article 29(1) – the general rule: transporting products within the EU, expressly including e-commerce. From 1 January 2030 economic operators using such packaging must “ensure that at least 40% of such packaging used is reusable packaging within a re-use system” – a threshold counted as the combined share across all formats, so a weaker result on one format can be made up on another. From 1 January 2040 the regulation names 70%, but uses softer wording here: operators “shall endeavour” to reach that level, unlike the wording used for the 40% threshold. In practice, once the stricter paragraphs 2 and 3 are taken out, the 40/70% regime is left mainly for cross-border trade between independent companies and, for instance, domestic shipments to consumers (paragraph 3 concerns supplies “to another economic operator”).

Article 29(2) and 29(3) – the closed B2B loop: reusable packaging only from 1 January 2030. The regulation splits this into two cases: Article 29(2), circulation within a group (an operator’s own sites plus linked and partner enterprises in the EU), and Article 29(3), trade between independent operators in the same Member State. In both cases the provision requires such packaging to be fit for re-use within a re-use system. No percentage figure appears in the provision itself, and in the first delegated decision the Commission describes the obligation as “re-use requirements (...) at the level of 100 %”. The practical conclusion for a Polish company: domestic B2B trade falls under a regime that goes further than the general target, and not under a “lighter” variant of it. A point on timing: the obligation to demonstrate that the targets have been met applies from 1 January 2030 or 18 months after the entry into force of the implementing act setting out the calculation methodology (the Commission is to adopt it by 30 June 2027), whichever date is the later (Article 30(3)–(4)).

The formats listed expressly in Article 29(1) are pallets, foldable plastic containers, boxes, trays, plastic crates, intermediate bulk containers (IBCs), pails, drums and canisters, “of every size and made of any material” – including flexible formats, together with pallet packaging (wraps) and straps used to stabilise and protect products on pallets. The provision covers transport packaging as well as sales packaging used to transport products. This is the typical circulating equipment of the warehouse and of transport: precisely the category of reusable transport packaging (RTP).

Hence a conclusion that surprises logistics directors: in domestic B2B trade and in circulation within a group, from 2030 only reusable packaging may be used, while the “milder” 40% (2030) / 70% (2040, an endeavour target) applies mainly to cross-border trade between independent companies. The rest of this article is about what those figures do not say.

An illustrative scenario (not a client case). A component manufacturer moves its products from two of its own plants to three regional warehouses in the same country, and from there to domestic distributors. The “plant → warehouse” and “economic operator → economic operator in the same country” loops fall from 2030 under the full reusability requirement (packaging fit for re-use within a re-use system). The export leg, between different operators in different countries, counts towards the 40% (2030) / 70% (2040, an endeavour target) target under Article 29(1). One and the same company therefore runs two different compliance clocks at once.

What Article 29 leaves out – the exclusions that change the maths

Article 29 is not only about thresholds. It is also a list of exclusions and exceptions that decide what really falls under the obligation, and they often settle the cost of implementation. The first group is the closed, four-point catalogue in Article 29(4): packaging used to transport dangerous goods (Directive 2008/68/EC); packaging designed to order for the individual requirements of the customer and used to transport oversized machinery, equipment and goods; flexible formats in direct contact with food, feed or food ingredients; and cardboard boxes. Micro-enterprises are treated separately: the exemption covers operators that in a given year made available no more than 1 000 kg of packaging in a Member State and hold micro-enterprise status (the conditions apply together, Article 29(13)). In addition, the regulation gives the Commission the instrument of delegated acts (Article 29(18)), which can establish further exemptions where the obligation would prove disproportionate.

The first such act already exists. On 25 February 2026 the European Commission adopted the first delegated act under PPWR, Delegated Decision (EU) 2026/429 (C(2026) 511), excluding pallet wraps and straps from the re-use requirement under Article 29(2) and (3) – that is, from circulation within a group and from supplies within the same Member State. The reason: disproportionately high adaptation costs if only reusable wraps and straps were used. This does not mean that wraps and straps disappear from the regulation: in applications covered by Article 29(1) they remain subject to the 40% target, and only the uses caught by paragraphs 2 and 3 drop out of the obligation. The decision was published in the Official Journal of the EU on 6 May 2026 and has applied since 26 May 2026. We devote a separate blog article to the mechanics of that act and to a forecast of the exclusions still to come. In parallel, on 5 June 2026 the Commission adopted the first interpretative guidelines on the substantive provisions of PPWR (Commission Notice C(2026) 3702, published in the Official Journal of the EU as C/2026/3084 of 10 June 2026), which cover, among other things, the re-use targets in Article 29.

For the practitioner one conclusion follows: before you calculate your percentage, you have to know what counts towards it. Classifying formats and loops – what is excluded, what falls under the general 40/70% target and what under the full reusability requirement – is the first step in any sensible compliance plan.

“Within a re-use system” – what the lawyer will not tell you

The four most important words in Article 29 are not the percentages but the phrase “within a re-use system”. Buying sturdier crates is not yet compliance with PPWR. A reusable container counts only once a system works around it: return logistics, washing and inspection, records of circulation, and an ownership model (an in-house pool or a pooling operator).

This is the difference between a lawyer’s perspective and a practitioner’s. The lawyer will say: “you have to reach 40%.” We, as a manufacturer whose containers have been circulating in such loops for decades, add the question the text of the regulation never puts directly and which decides everything: does the packaging come back to you? The redemption rate is the quiet hero of the whole of Article 29. If containers do not come back, the system closes neither economically nor in regulatory terms, and the “re-use percentage” declared on paper drifts away from what happens on the loading ramp.

Professor Henning Wilts, who heads the circular economy division at the Wuppertal Institut, put it plainly in an interview in July 2023: we will not manage entirely without plastics, but their consumption has to be cut, re-use systems strengthened and, above all, more plastic kept in circulation (Wuppertal Institut, Zukunftswissen podcast, 11 July 2023).

What Article 29 means for the container specification (the manufacturer’s perspective)

This is where the knowledge begins that no law-firm guide contains. Reusability is a design decision, taken long before the first cycle. The logic of single-use packaging is the reverse of RTP logic: a single-use item is optimised for one journey and the least possible material, whereas a reusable container is designed for hundreds of cycles, washing, folding and the return leg. We have been designing and making such packaging since 1985 and we know that logic from the production hall, not from a commentary on the provision.

A container specification under Article 29 touches at least several parameters: durability and mechanical resistance (the number of cycles without loss of function), the choice of material and how it behaves in industrial washing (temperatures, detergents), the folding or nesting ratio (the volume taken up on the empty return leg), load capacity and stability on the pallet, and hygiene, especially where there is contact with food. Industry data confirm the scale: reusable transport packaging reaches up to 120 re-use cycles with a service life of the order of 7–12 years (for RPC-type crates), according to Reusable Packaging Europe, factsheet 2022.

Rotation, the closed loop and the decision: an in-house pool or an operator

Why did the legislator set the bar highest precisely for B2B circulation inside one country and within a group? Because these are controllable loops: you know the endpoints, you know the partner, the distances are short and returns can be enforced organisationally. The “shorter” and more closed the loop, the higher the real redemption rate, and the more sense such a requirement makes. We devote a separate blog article to closed loops in industrial manufacturing (Article 29(2)).

With this comes the model decision: an in-house packaging pool or a pooling operator. For some companies pooling is cheaper and simpler (the operator supplies, washes and rotates the equipment); for others, at sufficient scale and with repeatable routes, an in-house loop wins. That is a genuine TCO choice, not a matter of fashion; we devote a separate article on pallet pooling to load carrier management models. To be straight about it: pooling is a market context and an option for the customer, not a service we are selling here.

And there is the thing a lawyer will not calculate, yet which decides whether implementation makes sense: this is an investment, not an automatic saving. Moving to RTP means outlay – equipment, washing, return logistics, records – that pays back over time through repeated cycles. But RTP is not a purchase made once and for all: the fleet wears out, some containers go missing or are damaged, so fleet replacement is a real, recurring cost item, not a one-off expense. That is why an honest TCO calculation is directional – it shows roughly from which year RTP becomes cheaper than single-use packaging – rather than a payback down to the month or an ROI in per cent. Three pillars of that calculation are shaky today: prices (variable, and a figure quoted without a date goes out of date fast), EPR (the legal framework is confirmed, but the specific rates and their escalation are an assumption and a forecast, not applicable law – we set out the difference between EPR and PPWR separately), and the data of the process itself, which many companies do not yet have. Anyone promising a universal threshold of “X cycles = payback” is selling a simplification.

Manufacturer or distributor – different roles, the same mechanism

Article 29 binds into one mechanism two roles that the market usually keeps apart. The manufacturer places the packaging on the market and is the first to decide how it is built. The distributor, the 3PL operator, wholesale and e-commerce take part in the circulation and carry re-use obligations too, which is still a blind spot in the awareness of the Polish market. The point is not whose logo is on the crate, but who actually keeps the loop running.

That is why the distinction in the title is not an ornament. If your company is a distributor and you assume that “the manufacturer will sort it out”, check which side of Article 29 you are really on. We deliberately do not name particular market operators: the obligations follow from the role in the loop, not from the name over the door.

Where to start – a plan for 2030

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

1. Take stock of your transport packaging and map the loops: inside the company, domestic B2B, cross-border.
2. Classify every loop and format: what falls under the full reusability requirement, what under the general 40/70% target and what is excluded (for example the wraps and straps exempted by Decision (EU) 2026/429).
3. Specify the container for cycles, together with an RTP manufacturer (durability, washing, folding, hygiene).
4. Pilot and measure rotation and the redemption rate on one controlled route.
5. Take the model decision: an in-house pool or an operator; records and return logistics.

If you want to work out first where your company stands, start with the PPWR knowledge hub and readiness audit, and for implementation detail turn to the sector pages: industrial manufacturing and intralogistics.

FAQ

When does Article 29 PPWR start to apply? Regulation (EU) 2025/40 has applied since 12 August 2026, but the re-use targets in Article 29 start later: the first thresholds from 1 January 2030, and the next level, an endeavour target of 70%, is set for 2040.

What re-use thresholds does Article 29 PPWR introduce? The general rule (Article 29(1)): at least 40% from 2030, and from 2040 an endeavour target of 70% (“shall endeavour”) for transport packaging used in the EU. Two derogations tighten that: circulation within a group (Article 29(2)) and supplies to another economic operator in the same Member State (Article 29(3)) – in both cases, from 2030, reusable packaging only.

What is a “re-use system”? It is not the packaging itself but the whole loop around it: return logistics, washing and inspection, records, and an ownership model (an in-house pool or an operator). A container counts towards the re-use target only when it genuinely circulates within such a system.

What does the re-use requirement in controlled loops involve? In “short”, controlled loops, transport packaging must from 2030 be fit for re-use within a re-use system in its entirety: in circulation within a group – the same sites plus linked and partner enterprises (Article 29(2)) – and on supplies to another economic operator in the same Member State (Article 29(3)). The provision itself does not settle whether that system has to be closed or open; Annex VI defines both variants.

Does Article 29 apply to distributors, or only to manufacturers? Both. Distributors, final distributors and fulfilment service providers are “economic operators” within the meaning of Article 3(12), so the re-use obligations reach 3PL and e-commerce as well – domestic B2B trade falls under Article 29(3) (reusable packaging only from 2030), not just the operators placing a product on the market.

Are pallet wraps and straps covered by the full reusability requirement? They are transport packaging, but the first delegated act under PPWR (Delegated Decision (EU) 2026/429, adopted on 25 February 2026, published in the Official Journal of the EU on 6 May 2026, applying since 26 May 2026) excludes them from the re-use requirement in within-company circulation and in domestic B2B. In applications covered by Article 29(1) they remain subject to the 40% target.