A PPWR delegated act is not a footnote to the regulation. It is the instrument the European Commission will use to fine-tune packaging obligations throughout the coming decade. It went to work for the first time on 25 February 2026, when the Commission adopted Delegated Decision (EU) 2026/429, exempting pallet wrap and straps from the re-use requirement in closed and domestic B2B loops (Article 29(2) and (3)). The decision was published in the Official Journal of the EU on 6 May 2026 and has applied since 26 May 2026. For compliance and strategy teams, what the exemption reveals matters more than the exemption itself: how the Commission decides what to relax, and how to read its next moves before they land. In this article we take that first decision apart (what, from when and how far it reaches), separate out what it does not change and, working from the mechanisms written into the regulation itself, show where to expect the acts that follow. This is reading between the lines, not a rehashed press release.

Key takeaways

  • On 25 February 2026 the Commission adopted the first delegated act under the PPWR, Delegated Decision (EU) 2026/429. It was published in the Official Journal of the EU on 6 May 2026 and has applied since 26 May 2026.
  • The decision exempts economic operators using pallet wrap and straps from the re-use requirement in Article 29(2) and (3) of the PPWR: that is, in transport within one and the same company, between linked or partner enterprises, and on supplies to another economic operator within the meaning of Article 3(12) in the same Member State.
  • This is not the disappearance of wrap from the PPWR. Wrap and straps remain covered by the general 40% target for reusable transport packaging from 1 January 2030 (Article 29(1)), as recital 1 of the decision states explicitly.
  • The reason for the exemption is disproportionate adaptation costs. The Commission pointed to the large up-front investment needed to redesign packing lines, and to automation that is not yet sufficiently developed (recitals 3–4 of the decision).
  • The forecast is not fortune-telling. The regulation sets out the next steps itself: a minimum number of rotations for reusable packaging (delegated act by 12 February 2027, Article 11(2)), design-for-recycling criteria and recyclability performance grades (by 1 January 2028, Article 6(4)) and a review of bio-based plastics (by 12 February 2028, Article 8). That is a timetable written into the law, not speculation.

  • The practical takeaway: do not redesign your strategy around a single exception. The decision narrows one obligation for two ancillary formats; the core of Article 29 (containers, crates and pallets in reusable circulation) stands untouched.

     

What a delegated act is in the PPWR – and why that matters more than one exception

The PPWR, Regulation (EU) 2025/40, entered into force on 11 February 2025 and applies from 12 August 2026. As a regulation it is binding directly in every Member State, with no national transposition. If you are only now coming to the subject, we cover the regulation as a whole in our introductory article. The text of the regulation is not a closed one, however. In many places the legislator deliberately left blank fields for the European Commission to fill in later, through delegated and implementing acts. This is a standard mechanism of EU law (delegation under Article 290 TFEU): the regulation sets the objective and the limits, and the Commission works out the technical detail, the calculation methods or, as here, the exemptions that apply where an obligation turns out to be disproportionate. In the PPWR the framework for exercising those powers is Article 64 (“Exercise of the delegation”), and the legal basis for exemptions from the re-use targets is Article 29(18). For compliance this has a practical consequence: the PPWR as it stands on 12 August 2026 is not the final version of the obligations. Some of the rules that will really drive costs, such as how the re-use share is calculated, how many rotations a piece of packaging has to complete and which formats are exempt, are still being written. Anyone who follows only the text of the regulation, and not the stream of delegated acts, is planning from an out-of-date map. That is why Decision (EU) 2026/429 is interesting twice over: as a specific exemption and as the first evidence of how the Commission intends to use the instrument.

What Decision (EU) 2026/429 actually exempts

Instrument and dates. The first delegated act under the PPWR is Commission Delegated Decision (EU) 2026/429, adopted on 25 February 2026 (known at draft stage as document C(2026) 511). After the period of objection of the European Parliament and of the Council had expired without effect, the decision was published in the Official Journal of the EU (L series) on 6 May 2026 and, under its Article 2, entered into force on the twentieth day following publication, that is on 26 May 2026. The legal basis is Article 29(18)(a) of the regulation. Scope. The heart of the decision is a single sentence. Article 1 reads: “Economic operators using pallet packaging and straps for the stabilisation and protection of products on pallets during transport are exempted from the requirements concerning the re-use of those packaging formats at the level of 100 %, laid down in Article 29(2) and (3) of Regulation (EU) 2025/40”. The legal wording, “pallet packaging and straps”, covers in practice stretch film (pallet wrap) and the binding straps used to secure a load on a pallet. The exemption applies to the loops governed by Article 29(2) and (3): transport within one and the same company or between linked and partner enterprises in the Union, and transport between enterprises in the same Member State. The reason. The Commission makes no secret of its motivation. In the recitals to the decision it points to “strong evidence” that using reusable wrap and straps exclusively in these operations could lead to disproportionate adaptation costs: it would call for large up-front investment in redesigning packing lines and in automated solutions that are “not yet sufficiently developed”, and in the worst case it could disrupt supply chains. Procedure – from draft to law. The route this decision took is a model one and worth remembering: the draft was open for public comment from 10 December 2025 to 9 January 2026 (the Commission consultation portal), adoption followed on 25 February 2026, then came the period of objection of the Parliament and the Council, publication in the Official Journal and entry into force 20 days later. The whole cycle, from draft to binding law, closed in under six months.

 

What this decision does NOT change – five things that stay

The commonest mistake with announcements of this kind is over-interpretation. “Pallet wrap exempted” can grow, as it travels, into “film is out of the PPWR” or “re-use has been watered down”. Neither is true. What stays as it was:

  1. The general 40% target stands. Pallet wrap and straps are still transport packaging and still count towards the 40% re-use target from 1 January 2030 (Article 29(1)). Recital 1 of the decision confirms this, and it also recalls that the 40% target is counted across all the formats used, taken together, so a low re-use share in one format can be offset by a high share in another.
  2. The other formats are unaffected. Pallets, collapsible crates, boxes, cases, trays, drums, jerrycans, IBCs: the rest of the transport-packaging catalogue falls under Article 29 exactly as before. The decision covers two ancillary formats, not the whole category.
  3. The re-use system requirement stays as the rule. For the remaining transport packaging in intra-company loops and in domestic trade between economic operators, the full reusability requirement within a re-use system still applies from 2030. One exception has changed, not the rule.
  4. The date of application of the PPWR does not move. The regulation applies from 12 August 2026, and the delegated decision delays nothing here.
  5. The design logic does not change. Reusability still cannot be bought off the shelf; it has to be designed in, through durability, the number of cycles, washing and reverse logistics. Exempting wrap invalidates none of those decisions, and we work through them in detail in our analysis of Article 29.

In other words, the first delegated decision is a surgical cut, not a change of course. Anyone who halts a re-use programme on the strength of it is reading the announcement back to front.

 

How to read this decision: it is a signal, not a loophole

Here begins the part you will not find in the press release. The first delegated act is valuable not because it lifts an obligation for two formats, but because it reveals the method. Three elements of the decision tell you how the Commission will reach the next ones. First, the trigger is “disproportionate cost”, not “inconvenience”. The Commission did not lift the obligation because the industry dislikes it. It did so after analysing evidence gathered from stakeholders, which showed the cost to be disproportionate to the effect in one specific, narrow application. That is a high bar, and it suggests where to look for the next exemptions: wherever a format is inherently hard to bring into a return loop, from materials that “vanish” in use, through formats of negligible mass compared with the load they secure, to applications that call for automation the market does not yet offer. Second, exemptions are narrow and tightly drawn. The decision does not say that wrap is exempt. It says that operators using these formats, for this purpose (stabilising and protecting products on pallets during transport), are exempt from this obligation, the requirement in paragraphs 2 and 3. Every further exemption will most likely be just as surgical, and just as easy to over-interpret. Third, the route is repeatable and open to view. Stakeholder input, draft, public consultation (the “Have Your Say” portal), adoption, period of objection, Official Journal. That route can be watched in advance: anyone monitoring the consultations and the register of delegated acts sees the next exemptions while they are still drafts, not after the event. It is worth looking at the legal basis itself as well. Article 29(18) allows the Commission to grant exemptions to economic operators “because of specific economic constraints faced in a given sector”, and it covers the targets in paragraphs 1, 2, 3, 5 and 6, so not only the full reusability requirement in paragraphs 2 and 3 but also the general 40% target and the targets for the beverage sector. Structurally, then, wider exemptions than this first one are possible. We do not assume in advance what will be exempted, or when. We point to the route such decisions travel and to the arguments the Commission accepts.

 

Forecast: what comes after the first delegated act

The strongest forecast is the one the text of the regulation supplies itself. The PPWR contains mandates for the Commission with specific deadlines: these are not scenarios but planned acts that have to be produced. Three of them matter most for transport packaging and re-use.

  • A minimum number of rotations for reusable packaging – delegated act by 12 February 2027 (Article 11(2)). The Commission is to set a minimum number of rotations for the most commonly used reusable packaging formats, taking hygiene and logistics requirements into account. Its practical weight is considerable: until it is settled how many rotations a piece of packaging must complete in order to count as reusable, the targets in Article 29 rest on a soft basis of calculation. This act is likely to change the working day of logistics teams more than the exemption for wrap does.
  • Design-for-recycling criteria and recyclability performance grades – delegated acts by 1 January 2028 (Article 6(4)). They will decide what can be placed on the market at all from 2030, and which recyclability grade a given piece of packaging is assigned.
  • Bio-based plastics – a review by 12 February 2028 (Article 8). Here is a point that many summaries miss: this is a mandate not for a delegated act but for a review of technological development and of the environmental performance of packaging made from bio-based plastics, after which the Commission will, where appropriate, bring forward a legislative proposal, for instance one allowing bio-based feedstock as an alternative to recycled content towards the targets in Article 7. A different procedure and a longer road, but the same stream of change that has to be watched.

Alongside these planned items there is a second layer: further exemptions along the lines of Decision 2026/429 (Article 29(18)). The honest forecast here is that the mechanism is open but nobody has announced anything specific. Every further exemption calls for its own analysis of the evidence, a public consultation and passage through a period of objection. How to monitor this in practice: follow the Commission consultation portal (“Have Your Say”) under the PPWR heading, the register of delegated acts and the Official Journal of the EU. The early signal is a consultation opening on a draft; the hard signal is publication in the Official Journal.

 

What this means for manufacturers and distributors – perspective, not headline

From the standpoint of a manufacturer of reusable packaging, and we have been designing and producing it at bekuplast since 1985, Decision 2026/429 overturns nothing, but it does teach you how to respond to the ones that follow. Three operational conclusions: 1. Classify your formats and loops before you count percentages. Wrap and straps show that the mapping of format to obligation can change with a single delegated act. A sensible compliance plan starts with a map: which packaging, in which loops (intra-company, domestic B2B, cross-border), under which regime (general 40% target, closed loop system, exempt). That map has to be treated as a living document, updated after every act. 2. Do not build a strategy on a single exception. The exemption for wrap is not an argument for halting investment in re-use, because it concerns one obligation for two lightweight securing formats. The core of Article 29, meaning containers, pallets and cases in reusable circulation, remains. Design decisions for reusable circulation, from durability and the number of cycles to washing, folding and reverse logistics, are as relevant as they were. 3. Read the acts as cost signals, not as marketing. Every delegated act moves the boundary between what is mandatory and what pays for itself even without an obligation. An exemption from the requirement in paragraphs 2 and 3 does not mean that re-using wrap stops making economic sense; it means only that it stops being mandatory in that loop. That distinction, regulatory cost against your own calculation, is the heart of a level-headed response to the PPWR. And one caveat about the arithmetic: returnable packaging is not a matter of buying once and for all, because the fleet wears out and shrinks, so the calculation has to include fleet replacement as a real and recurring cost, alongside washing and reverse logistics. That is why we consistently treat re-use as an investment with a directional return: what counts is the point at which returnable packaging becomes cheaper than single-use, not a promise of how much you will save. We set out the methodology formula by formula in our article on the TCO calculator, and the PPWR cost calculator in the PPWR knowledge hub gives a directional figure for your own process.

An illustrative scenario (not a client case). A components manufacturer ships its products from its own plant to warehouses in the same country, securing the pallets with film and straps. After Decision 2026/429, that wrap and those straps are no longer subject, in that domestic loop, to the re-use requirement in paragraphs 2 and 3 – but the pallets and crates the components travel in still fall under the Article 29 regime. If that manufacturer read the announcement as the PPWR easing off, it would stop the re-use programme for containers the exemption does not touch at all, and would wake up with a compliance gap in 2030. One exemption changes one line in the spreadsheet, not the whole spreadsheet. For solutions matched to loops of this kind, see our page for industrial manufacturing.

A separate thread, which we only flag here, is the digital layer of the PPWR: labelling, counting rotations and the traceability of reusable packaging (RFID, the product passport). We cover it at greater length in our article on the Digital Product Passport (#17; hyperlink to follow once it is published).

 

FAQ

What is a PPWR delegated act? It is a legal act of the European Commission which, under the delegation set out in Regulation (EU) 2025/40 (Article 64), settles the technical detail, the calculation methods or the exemptions that the text of the PPWR leaves open. The first such act is Delegated Decision (EU) 2026/429, adopted on 25 February 2026. 

What did the first PPWR delegated act exempt? It exempted economic operators using pallet wrap (pallet packaging) and straps to stabilise and protect products on pallets from the re-use requirement in Article 29(2) and (3), that is, in transport within a company, between linked or partner enterprises, and on domestic B2B supplies. 

Is pallet wrap out of the PPWR now? No. Wrap and straps have been exempted only from the requirement for closed and domestic loops (Article 29(2) and (3)). They are still transport packaging and still count towards the general 40% re-use target from 1 January 2030 (Article 29(1)). 

When did the exemption take effect? Decision (EU) 2026/429 was published in the Official Journal of the EU on 6 May 2026 and entered into force on the twentieth day following publication, that is on 26 May 2026. 

Which PPWR delegated acts are due next? The regulation gives the Commission deadlines: a minimum number of rotations for reusable packaging, a delegated act due by 12 February 2027 (Article 11(2)); design-for-recycling criteria and recyclability performance grades, due by 1 January 2028 (Article 6(4)). By 12 February 2028 the Commission is also to review bio-based plastics (Article 8), which is a review with a possible legislative proposal, not a delegated act. Further exemptions under Article 29(18) are possible as well. 

Should we pause our re-use programme now that wrap is exempt? There are no grounds for it. The exemption concerns one obligation for two lightweight ancillary formats. The re-use targets for pallets, crates and the rest of transport packaging remain in force, and design decisions for reusable circulation are still valid.