Transport packaging rules and the PPWR: 40% reusable by 2030

MONDAY, 28 SEPTEMBER 2026

For importers the obligation starts at the first European warehouse. Cardboard boxes are excluded, pallets and plastic crates are not.

Transport packaging rules under the PPWR, the EU packaging regulation, require at least 40% of it to be reusable by 2030, and for importers the obligation starts at the first warehouse in the Union where the goods are unloaded. Regulation (EU) 2025/40 has applied since 12 August 2026, and the guidance the Commission published in early June clarified several points that directly concern those who buy outside Europe.

What the PPWR transport packaging rules provide

Article 29 of the regulation sets reuse targets for packaging used to move goods, not to present them to the consumer: pallets, foldable plastic boxes and crates, trays, intermediate bulk containers, pails, drums, canisters, flexible formats, wrapping and straps. The operator using them must ensure that a growing share is reusable and part of a reuse system, meaning it comes back and is used again.

• 12 August 2026: application date of Regulation (EU) 2025/40 on packaging and packaging waste.
• 5 June 2026: the Commission publishes its notice with practical guidance on applying the regulation.
• 40%: the minimum share of reusable transport packaging to be reached by 2030.
• 70%: the 2040 target, worded as a commitment to strive for it rather than a binding result.
• 50%: the maximum empty space in grouped, transport and e-commerce packaging from 1 January 2030, or three years after the act on the calculation method if that comes later.

Who must meet the targets

The obligation falls on the operator that uses the transport packaging and places the product on the Union market: this can be the manufacturer, the importer or the distributor. For sales packaging, the rule applies only where it has an evident transport function, for example through a shape, size or design meant for handling.

The guidance also clarifies the most delicate point for those buying abroad. For goods from third countries the targets apply from the moment of import, that is, from the first warehouse in the Union where the goods arrive, are stored and unpacked before distribution. A shipment sent directly to a single final destination does not need to be repacked; a distribution centre, however, does not count as a final destination.

The exclusions: cardboard, dangerous goods, food

The reuse targets of Article 29 do not apply to packaging used for dangerous goods, to custom packaging for large machinery, to flexible formats in direct contact with food and feed, or to cardboard boxes. For wrapping and straps used to stabilise loads on pallets, Delegated Decision (EU) 2026/429 removed the full-reuse obligations set in certain cases, but these materials remain in the 40% calculation.

The cardboard exclusion is the most relevant for importers of consumer goods and promotional items, which largely arrive in corrugated cardboard cartons. It does not, however, cover the pallets those cartons travel on, nor plastic crates or drums: that is where the 2030 target will be felt.

What it means for importers

The data does not say that every importer must replace its packaging tomorrow: 40% is a 2030 target and the guidance ties the obligation to the first European warehouse, not to the ocean leg. It does signal that transport packaging is entering purchasing specifications, and it is worth raising it with suppliers now, while orders for 2027 and 2028 are being negotiated.

Three concrete checks. Which formats arrive today at the first warehouse: cartons excluded, pallets and plastic crates in scope. Who handles the return of pallets and reusable packaging after unloading, because a reuse system requires someone to take them back. And how much empty space the parcels contain, since the 50% limit from 2030 also covers grouped and transport packaging: generous padding and oversized boxes today cost only in freight, tomorrow in compliance too.

The role of the packing specification

Many companies leave packing to the supplier, who picks the cheapest solution for itself. Under the PPWR that choice has consequences for whoever places the goods on the European market, so it pays to make the packing specification part of the order: material, carton size relative to the product, pallet type and what happens to it after unloading.

With La Merce, an order imported from 2026 starts with the packing specification agreed at the factory: corrugated cardboard where possible, empty space below 50% and pallets designed for reuse from the first European warehouse onwards.

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