From 2030 the PPWR asks for 40% reusable transport packaging, but on own-site and domestic routes it asks for all of it, and cardboard boxes sit outside every target

What Article 29 actually says

The PPWR has applied since 12 August 2026, but Article 29 sets its reuse duties from 1 January 2030. It places the targets on economic operators rather than on Member States, which recital 94 explains, and it ties them to a re-use system: recital 86 asks users of reusable packaging to ensure one exists, open or closed loop (EUR-Lex, recitals; PR-EU-006). Exhibit 2 maps the paragraphs that matter for transport and grouped packaging.

Paragraph 1, the 40% pool. The listed forms are pallets, foldable plastic boxes, boxes, trays, plastic crates, intermediate bulk containers, pails, drums and canisters, of any size or material, including flexible formats and pallet wrappings or straps used to stabilise and protect products on pallets. The rule covers transport packaging and sales packaging used for transporting products, including products sold through e-commerce. The 2030 level is an obligation of result; the 2040 level is worded as “shall endeavour” (Article 29(1)).

Paragraphs 2 and 3, the 100% routes. Both are written as derogations from paragraph 1. Paragraph 2 covers transport between sites where the operator carries out its activity, or between those sites and the sites of linked or partner enterprises as defined in Recommendation 2003/361/EC. Paragraph 3 covers delivery to another economic operator within the same Member State. The Commission’s guidance says no percentage applies on these routes: the packaging must be reusable within a re-use system (Commission Notice C/2026/3084, section 19). Recital 95 names the formats it has in mind for these routes: pallets, foldable plastic boxes, plastic crates, intermediate bulk containers, both rigid and flexible, and drums.

Paragraph 5, grouped packaging. Boxes used outside sales packaging to group a number of products into a stock keeping or distribution unit must be 10% reusable from 2030, with 25% as an aim for 2040. Cardboard is excluded from this paragraph too. The European Parliament’s summary of the regulation records the two binding levels as 40% for transport and sales packaging and 10% for grouped packaging (EP Legislative Observatory).

Paragraph 17, the count. Every target is calculated per calendar year. For an operator with a July to June financial year, that means a second data cut from 2030.

What sits outside the targets

Exhibit 3 sets out every route out of the transport and grouped targets that SPI found in the text, in the guidance or in the 2026 delegated decision. They fall into three groups: formats, operators and Member State decisions.

Cardboard. The cardboard exclusion is the largest by tonnage. Recital 95 explains that the number of rotations of cardboard boxes is very low, so they are not required to be reusable. Paper and cardboard were 40.4% of the 79.7 million tonnes of EU packaging waste in 2023, or 32.3 million tonnes, although not all of it is boxes (Eurostat Statistics Explained). The practical effect is that an operator can meet the 100% rule on a domestic route by shipping in cardboard boxes on reusable pallets, a point SPI’s e-commerce piece develops for parcels.

Wraps and straps. The Commission adopted the decision under Article 29(18)(a), which allows exemptions for economic constraints in a specific sector. Its recitals say that exclusive use of reusable wraps and straps on 100% routes can cause disproportionate adaptation costs, and its explanatory memorandum cites about 600,000 logistics businesses, on Eurostat data, and costs of about EUR 610 million for packaging line changes, automated wrapping machines, IT and training (Council ST 6986/26). The draft was open for feedback from 10 December 2025 to 9 January 2026 (European Commission, DG ENV news, 25 February 2026). AGRINFO’s reading is that operators using wraps or straps must still meet the overall 40% target from 1 January 2030.

Small operators. Article 29(13) exempts an operator for a calendar year only if both tests are met: no more than 1,000 kg of packaging placed on the market in a Member State’s territory, and the micro-enterprise definition in Recommendation 2003/361/EC. An industry guide on industrial and commercial packaging summarises that definition as fewer than 10 employees and turnover or balance sheet total of no more than EUR 2 million (IK guide, 16 December 2024). The Commission may change the 1,000 kg threshold by delegated act. SPI has not yet confirmed how many EU operators fall under it.

National exemptions. Article 29(14) lets a Member State exempt operators for five years if it beats the 2025 recycling targets by 5 percentage points per material and is expected to do so for 2030, shows at least a 3% cut in packaging waste per head by 2028 against 2018, and the operator has a waste prevention and recycling plan. The Commission reads the material test as material by material, so a strong result on one material can lift only the matching part of an obligation (Commission Notice, section 24). Renewal requires the 2035 and 2040 prevention targets to be met.

A framework: the route and format screen

SPI’s organising device for this piece is a two-question screen. The first question is the format: is it on the Article 29(1) list, on the grouped list in 29(5), or excluded? The second is the route: does the packaging move between own sites, to another operator in the same Member State, or across a border? Exhibit 4 sets out the five lanes that result.

Lane A and lane B carry the heaviest duty and are where the planning effort should start. A food manufacturer delivering from its own plant to its own warehouse is in lane A; the same manufacturer delivering to a retailer’s distribution centre in the same country is in lane B. Both need reusable pallets and crates for every trip from 2030.

Lane C is a pool. Cross-border flows inside the Union, and imports counted from the first EU warehouse, fall here. The Commission says a consignment going from the first warehouse to a single final destination need not be unpacked and repacked, but distribution centres and logistics hubs are not final destinations, so onward flows count (Commission Notice, section 19).

Lane D is easy to overlook. Grouped boxes that never reach the consumer as sales packaging, such as plastic trays that hold several packs on a shelf, have their own 10% target.

Lane E is where most corrugated packaging sits.

Sales packaging with a transport function

Article 29(1) reaches beyond transport packaging to sales packaging used for transporting products. The Commission’s June 2026 guidance explains the test with examples, which Exhibit 5 sets beside the formats an industry study examined.

The fruit crate example matters for the grocery chain. Because a crate of fruit holds more than one portion and is shipped to the point of sale, the Commission counts it as sales packaging used for transport (Commission Notice, section 18). It therefore sits in lanes A to C, not in the grouped lane, and on a domestic supplier to retailer route it is in the 100% lane.

The BKV study points the other way for chemicals. Its interviewees said new PE drums and FIBCs cost much less than reusable versions, and that the line between transport packaging and sales packaging with a transport function was neither clear nor reasonable to them (BKV, February 2026). Article 29(18)(b) and (c) give the Commission power to add exemptions where hygiene, food safety or environmental aspects prevent the targets being met, and BKV’s study is framed as a case for such exemptions. SPI has not yet confirmed any Commission plan for a second delegated act under Article 29(18).

The tonnage behind the targets

Eurostat’s latest Statistics Explained figures, for 2023, put EU packaging waste at 79.7 million tonnes, or 177.8 kg per person. The Brussels Times reported on 22 October 2026 that Eurostat’s 2024 data put the total at 81.5 million tonnes, or 181.0 kg per person; SPI has not yet confirmed those figures in Eurostat’s own release. Exhibit 6 shows the 2023 material shares, which give a first sense of how much tonnage the format list and the cardboard exclusion touch.

Wood is almost entirely pallets, crates and cable drums. It was 12.6 million tonnes of EU packaging waste in 2023, against a 2030 recycling target of 30% (Eurostat). Every new pallet that becomes a pooled pallet takes tonnage out of that waste stream, which is why the reuse targets sit in the same chapter as the prevention targets of Article 43. SPI’s steel and wood piece sets out how nine euro EPR schemes price new, reused and repaired pallets today; this piece does not repeat those rates.

Plastic, at 19.8% in 2023, is where crates, trays, drums, IBCs and stretch film sit. It is also the material on which most of the reusable formats in Exhibit 5 are built.

Scenarios: what 40% really means for one operator

The 40% figure applies to lane C only. For an operator whose flows are mostly domestic, the 100% lanes do most of the work. Exhibit 7 shows the effect on one operator that uses 500,000 equivalent units of listed formats a year, the unit Article 30(1) counts in.

SPI calculation, base case. With 50% of units on lanes A and B, 250,000 units must be reusable at 100% and the other 250,000 at 40%, which is 100,000 more: 350,000 units, or 70.0%. If a quarter of all units are wraps and straps, 62,500 of the domestic units move into the pool, so 187,500 domestic units stay at 100% and 312,500 units sit in the pool at 40%, which is 125,000. The total is 312,500, or 62.5%.

The spread between low and high is the point. An exporter with 20% of its units on domestic routes needs about half of its listed packaging reusable; a domestic distributor with 80% needs three quarters to nine tenths. The wrap decision cuts the high case by 12 points, which explains why the Commission described the 100% rule for wraps as disruptive for logistics businesses (AGRINFO).

Two counting questions remain open. First, the Article 30(3) implementing act may count lane A and B units in the 40% denominator, which would lower the required share in every column; SPI has not yet confirmed its draft. Second, Article 30(4) says the duty to demonstrate the targets applies from 1 January 2030 or 18 months after that act enters into force, whichever is later, so a late act moves the first year of proof (Article 30, German text as reproduced).

Luxembourg: what reuse does to a fee bill

SPI’s fee data hold one scheme with an explicit reusable line, Luxembourg’s Valorlux, which makes it a clean test of the fee side of the switch. Valorlux’s PV00 line, reusable packaging, is EUR 0.0000 per kg in 2025, 2026 and 2027 (Valorlux 2026 and 2027 tables). Exhibit 8 sets it against the lines that single-use transport and grouped packaging would otherwise pay.

Transport packaging is non-household packaging under Article 3 point 8 of Luxembourg’s 2017 packaging law. The environment administration’s December 2025 guide names pallets and stretch film as examples, leaves them out of its household guidance, and says a business that generates them must also comply (AEV guide, December 2025). Valorlux’s industrial lines are the ones SPI’s data hold for that flow. SPI’s Benelux piece covers the rest of the Valorlux table and Luxembourg’s own reuse rules.

To size the fee effect, SPI priced one Luxembourg wholesaler that delivers to shops in Luxembourg, lane B in Exhibit 4, with 40 tonnes of single-use plastic crates, 15 tonnes of PE stretch wrap and 60 tonnes of cardboard boxes a year.

SPI calculation. 40 x 39.5 = EUR 1,580; 15 x 39.5 = EUR 592.50; 60 x 14.5 = EUR 870. The total is EUR 3,042.50, and removing the crates leaves EUR 1,462.50, 51.9% lower. On the household PP line the same crates would cost 40 x 427.9 = EUR 17,116 in 2026 and 40 x 495.8 = EUR 19,832 in 2027, 10.8 and 12.6 times the industrial line.

The pools that already exist

Reusable pallet and crate pools are an existing industry, not a 2030 invention. Exhibit 10 sets out what two of the largest pool operators report, each in its own unit.

Who counts, who reports and when

The targets come with a counting rule and a reporting duty. Article 30(1) asks users to count, per calendar year, the equivalent units of listed formats that are reusable within a re-use system and those that are not, separately for the transport and grouped targets. Article 31 then asks the operators in Article 29(1) to (8) to report those data to the competent authority each year, within six months of the year end, with 2030 as the first reporting year (Articles 30 and 31, German text as reproduced). Exhibit 11 sets out the roles.

The Commission’s guidance is clear on who the user is: the operator that places a product on the Union market in the relevant transport packaging, whether manufacturer, importer or distributor (Commission Notice, section 20). That puts the target on the shipper, not on the pool operator or the haulier. A brand that buys pooled pallets is still the party that reports.

Penalties are national. SPI’s tracker entry records that the EU sources give no amount, so an operator with flows in several Member States faces several penalty regimes for the same shortfall (PR-EU-006). National layers can also add targets. Article 8 of Spain’s Royal Decree 1055/2022 already sets reuse targets of 20% and 30% for commercial and industrial packaging, and France’s national reuse threshold reaches 10% in 2027 (PR-ES-002; PR-FR-001). Article 29(15) allows such higher national targets where they are needed for the Article 43 prevention goals.

Reuse also interacts with two other 2030 rules. Recital 84 takes reusable packaging out of the 50% empty space limit for grouped, transport and e-commerce packaging, so a flow moved into reusable crates steps outside Article 24 (PR-EU-009). And a reusable plastic grouped tray that replaces a single-use one counts toward the 10% grouped target while it avoids the Annex V format questions that SPI’s quick-service restaurant piece covers for food service.