EU: Packaging and Packaging Waste – exemptions from the reuse obligations for plastic wrappings and straps

 

The EU Commission has published a draft delegated act that would establish exemptions from the PPWR’s reuse obligations for plastic wrappings and straps.

Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, which amends Regulation (EU) 2019/1020 and Directive (EU) 2019/904 and repeals Directive 94/62/EC, introduces reuse targets for certain packaging formats, applicable from 2030.

Under this Regulation, from 1 January 2030 economic operators using transport packaging, or sales packaging used for the transport of products—including goods distributed through e-commerce—within the Union, in the form of pallets, foldable plastic boxes, boxes, trays, plastic crates, intermediate bulk containers, pails, drums and canisters of any size or material, as well as flexible formats or pallet wrappings and straps used to stabilise and protect goods during transport, must ensure that at least 40 % of such packaging, taken as a whole, consists of reusable packaging within a reuse system.

In addition, economic operators using transport packaging or sales packaging for transport in the same formats within the Union, for movements between their own operational sites, between their sites and those of linked or partner enterprises, or for deliveries to another economic operator within the same Member State, are required to ensure that such packaging is always reusable within a reuse system.

Taking into account the most recent scientific and economic evidence and developments, the Commission is empowered to grant additional exemptions for economic operators, beyond those already provided for in the Regulation, where specific sectors face particular economic constraints in meeting the targets set out in Article 29(1), (2), (3), (5) and (6).

This Delegated Decision applies to economic operators that use pallet wrapping and strapping in their transport operations. According to Eurostat, approximately 600 000 businesses in the EU could be affected by Article 29(2) and (3). The estimated compliance costs for these businesses amount to around EUR 610 million and mainly relate to adapting packaging lines—often requiring parallel packaging systems—as well as investments in new automated pallet-wrapping machinery, IT systems and staff training. For competent authorities, the main costs are associated with conducting audits to verify compliance with the reuse obligations laid down in Article 29(2) and (3).

To find out more about compliance for packaging and the EU Packaging and Waste Packaging Regulation, do not hesitate to contact the Product Compliance Institute.