EU packaging · PPWR Reg (EU) 2025/40
Does your packaging fall under a PPWR reuse target?
The PPWR sets reuse targets and obligations for certain packaging formats from 2027 onward. Pick your format and find out which reuse obligation applies — and the timeline of deadlines.
PPWR reuse verdict
Reuse target appliesTransport/sales reuse target applies
Your transport and sales packaging is subject to the PPWR reuse target. See the timeline below. Pallet wrapping and straps used for stabilisation are exempt from the 100% reuse requirement.
- 2030At least 40% of transport and sales packaging reusable (pallets, boxes, trays, crates, IBCs, pails, drums, canisters) from 1 January 2030.
The rule, in one line
Under the PPWR (Regulation (EU) 2025/40, Article 29), at least 40% of transport and sales packaging (pallets, boxes, trays, crates, IBCs, drums, canisters) must be reusable from 1 January 2030; beverage distributors must offer 10% of products in reusable packaging by 2030, rising to 40% by 2040 (with exemptions for microenterprises and small distributors); and restaurants and cafes must let consumers bring their own container by 2027 and offer reusable takeaway packaging by 2028. Pallet wrapping and straps are exempt from the 100% reuse requirement.
- 2027
- Takeaway: consumers may bring their own container at no extra cost.
- 2030
- Transport/sales packaging ≥40% reusable; beverages 10% reusable.
- 2040
- Beverage reuse target rises to 40%.
Official sources: Regulation (EU) 2025/40 · European Commission — PPWR · EC — pallet-wrapping exemption
What this tool is — and isn't
This checker tells you whether your packaging format falls under a PPWR reuse target/obligation and the headline timeline (Regulation (EU) 2025/40, EUR-Lex + the European Commission). It is an estimate and orientation, not legal advice, and it does not compute your exact reusable share, list every sub-target or exemption, or cover national derogations. Verify against the linked official sources.
How the determination works
1. Pick the format
The PPWR reuse targets apply to specific contexts — transport and sales packaging, beverages, and takeaway food/beverage. You pick the closest match.
2. The target + timeline
Each format has its own deadlines: 40% of transport/sales packaging reusable from 2030; beverages 10% by 2030 and 40% by 2040; takeaway own-container by 2027 and reusable offer by 2028.
3. Exemptions
Microenterprises and small beverage distributors are exempt from the beverage targets, and pallet wrapping and straps are exempt from the 100% reuse requirement.
Frequently asked questions
- Which packaging must be reusable from 2030?
- At least 40% of transport and sales packaging — pallets, foldable plastic boxes, boxes, trays, plastic crates, intermediate bulk containers, pails, drums and canisters — from 1 January 2030.
- What are the beverage targets?
- Beverage distributors must offer 10% of products in reusable packaging by 2030, rising to 40% by 2040 — with exemptions for microenterprises and small distributors and certain sectors.
- What changes for takeaway?
- Restaurants and cafes must let consumers bring their own container at no extra cost by 2027, and offer reusable takeaway packaging at no extra cost by 2028.
- Are pallet wrapping and straps caught?
- No. Pallet wrapping and straps used to stabilise and protect products on pallets during transport are exempt from the 100% reuse requirement.
- My format isn't listed — am I done?
- The reuse targets do not apply to formats outside the list, but other PPWR rules — recyclability, recycled content, packaging minimisation, labelling — may still apply.
- Is this legal advice?
- No. This tool tells you whether your format falls under a PPWR reuse target and the headline timeline. It is orientation, not legal advice, and does not compute your exact share. Verify against the linked official sources.
The full Article 29 map: every PPWR reuse target side by side
The checker above answers one question — whether a reuse target binds your format. This table is the wider map: every binding 2030 target and every indicative 2040 goal that Article 29 of Regulation (EU) 2025/40 sets, and who each one binds.
| Packaging in scope — and who it binds | 2030 (binding) | 2040 (goal) |
|---|---|---|
| Transport and sales packaging used to ship products inside the EU, including e-commerce — pallets, foldable plastic boxes, boxes, trays, plastic crates, intermediate bulk containers, pails, drums and canisters, of any size or material (cardboard excluded). Binds every economic operator that uses it. | ≥ 40% reusable from 1 Jan 2030 | 70% (indicative) |
| The same transport packaging moved between different sites of one economic operator, or between linked or partner enterprises. | 100% reusable from 1 Jan 2030 | 100% |
| Transport packaging moved between economic operators within one member state. | 100% reusable from 1 Jan 2030 | 100% |
| Grouped packaging — boxes used to bundle sales units into a stock-keeping or distribution unit, excluding cardboard. | 10% from 1 Jan 2030 | 25% (indicative) |
| Beverages made available to consumers in sales packaging. Binds final distributors — with the drink and seller exemptions below. | 10% from 1 Jan 2030 | 40% (indicative) |
Three honesty notes on reading that table. First, the percentages are measured per calendar year, and only packaging circulating within a system for re-use counts — a crate that could be reused but never re-enters a return loop earns nothing. Second, the 2040 figures are endeavour goals the regulation asks operators to work towards, not binding law. Third, pallet wrapping and straps sit inside the 40% baseline list, but the Commission exempted them from the 100% same-operator requirement by delegated decision of 25 February 2026, after a feasibility study found that mandatory reusable wrappings would carry disproportionate adaptation costs.
Source: Art. 29, Regulation (EU) 2025/40, OJ L, 22.1.2025 — re-checked 2026-07-04; European Commission, pallet wrapping & straps exemption, 25 Feb 2026.
Cardboard is exempt from the reuse targets — but not from the PPWR
The most-searched exemption is real: cardboard boxes are carved out of both the transport-packaging targets and the grouped-packaging target. The Council’s adoption release (16 December 2024) puts it plainly: cardboard packaging is generally exempted from the re-use targets. The logic is material-specific — fibre loses integrity over repeated washing-and-return cycles, and cardboard already runs one of the EU’s highest-performing recycling loops.
What the exemption does not do is take cardboard out of the regulation. A seller shipping in cardboard still owes, on the ordinary PPWR calendar:
- the declaration of conformity and technical documentation for packaging placed on the market from 12 August 2026;
- recyclability design grades — from 1 January 2030 only packaging graded A to C may be marketed;
- harmonised material labelling on the packaging itself from 12 August 2028;
- the 50% empty-space cap for grouped, transport and e-commerce packaging from 2030 — cardboard boxes very much included;
- EPR registration and fees in every member state where it sells.
Sources: Council of the EU, 16 Dec 2024; timeline per Reg (EU) 2025/40 and the Commission’s PPWR guidance (March 2026).
Takeaway: what changes on 12 February 2027 — and again a year later
The takeaway duties arrive in two waves, and they are service obligations, not percentages. From 12 February 2027 (Article 32), final distributors selling hot or cold beverages or ready-prepared food for takeaway must let customers bring their own container, fill it at no extra charge and under conditions no less favourable than single-use, and visibly inform customers of the option at the point of sale.
From 12 February 2028 (Article 33), the same businesses must themselves offer a reusable-packaging option for takeaway. The 2028 duty carries the one size-based escape: microenterprises — fewer than 10 staff and no more than €2 million turnover or balance-sheet total — are exempt from offering reusable packaging, but not from accepting a customer’s own container in 2027.
Source: Arts. 32–33, Reg (EU) 2025/40, re-checked 2026-07-04; microenterprise definition per Commission Recommendation 2003/361/EC.
Beverage-target exemptions: which drinks and which sellers are out
The 10%-by-2030 beverage duty carries the regulation’s longest exemption list. Out of scope by drink: highly perishable beverages (within the meaning of Art. 24 of Regulation (EU) No 1169/2011) together with milk and milk products; grapevine products (wine); aromatised wine products; drinks made from fruit other than grapes or from vegetables that resemble wine, and other fermented beverages; and spirit drinks.
Out of scope by seller: microenterprises and small final distributors — the checkbox in the tool above — and member states may additionally exempt final distributors with a sales area of no more than 100 m² and outlets on small islands or in remote areas. There is also a system-level valve: a member state that beats its recycling targets by five percentage points and is on track on waste prevention may exempt operators from the reuse targets for a renewable five-year period.
One practical clarification from the Commission’s 2026 guidance, relevant to pubs and bottle shops: a business-to-business container such as a beer keg counts toward a final distributor’s 10% only where the filled container itself is made available to the end consumer.
Sources: Art. 29, Reg (EU) 2025/40; Commission PPWR guidance C(2026) 3702 and press release IP/26/664 (March 2026).
Who counts as an “economic operator” — and where an online seller fits
Article 3 defines the economic operators the reuse chapter binds: the manufacturer, the packaging supplier, the importer, the distributor, the authorised representative, the final distributor and the fulfilment service provider. In an e-commerce chain, nearly everyone is one of these:
| Role | Where a typical online seller fits |
|---|---|
| Manufacturer | You sell packaged products under your own name or trademark — even when a contract manufacturer produces and fills them. |
| Importer | You bring packaged products into the EU from outside — the standard position of a marketplace seller sourcing from a third country. |
| Distributor / final distributor | You make packaged products available downstream; the final distributor hands them to the end user — the role the beverage and takeaway duties attach to. |
| Fulfilment service provider | An EU warehouse that stores, packs or dispatches for third-party sellers without owning the goods. |
Two wiring rules matter in practice. An importer or distributor that sells under its own brand, or modifies packaging already on the market in a way that could affect compliance, inherits the manufacturer’s duties. And Article 29 expressly lets operators appoint a third party to run a mutualised re-use system — pallet pooling is the classic case — in which case the reuse obligations are met by that third party on the operators’ behalf.
Source: Arts. 3 and 29, Reg (EU) 2025/40, re-checked 2026-07-04.
More questions sellers ask
- Does my e-commerce shipping box count toward the 40% target?
- The 40% transport-packaging target explicitly includes e-commerce shipments inside the EU — but the box format most online sellers actually use is cardboard, which is exempt from the reuse targets. Ship in plastic crates, trays, pails or drums and the target does count you. Source: Art. 29(1), Reg (EU) 2025/40.
- Are the 2040 numbers legally binding?
- No. The 2030 targets are binding; the 2040 figures (70% transport, 25% grouped, 40% beverages) are indicative goals operators must endeavour to reach, subject to a Commission review. Source: Art. 29, Reg (EU) 2025/40.
- What happens if an operator misses a 2030 target?
- Penalties are national, not EU-level: the regulation obliges each member state to lay down effective, proportionate and dissuasive penalties and to enforce through its market surveillance authorities. There is no single EU fine schedule, so expect the numbers — and the enforcement appetite — to vary by country. Source: Art. 68, Reg (EU) 2025/40.
- Can I outsource the reuse obligation to a pooling provider?
- Yes. Article 29 lets economic operators appoint a third party to run a mutualised re-use system, and the obligations are then met by that third party on their behalf — which is how most operators are expected to hit the pallet and crate targets in practice. Source: Art. 29, Reg (EU) 2025/40.
- Where do I check the fine print before committing budget?
- Two documents: the Official Journal text of Regulation (EU) 2025/40 is the law, and the Commission’s March-2026 guidance document and FAQ is the interpretive reference member-state authorities will lean on while the implementing acts land.