PPWR · Regulation (EU) 2025/40

The PPWR for reusable transport packaging, from A to Z.

22 Jan2025
11 Feb2025
25 Feb2026
Jun2026
12 Aug2026
12 Aug2026
12 Feb2027
30 Jun2027
1 Jan2028
12 Feb2029
1 Jan2030
30 Jun2031
Feb2032
1 Jan2034
1 Jan2040

What is the PPWR?

Since 12 August 2026 the EU packaging regulation has applied directly across the EU. What does it ask of companies that work with crates, pallets, boxes, trolleys and roll containers? When, of whom, and what must you be able to show? Everything on one page, with the articles and the official links.

It is a regulation

No national law needed: the PPWR has applied directly since 12 August 2026. The heaviest duties for transport packaging build up towards 2030.

The user carries the target

The reuse targets fall on the company that uses the packaging to transport products, not on its maker (Commission guidance, §20).

40% and 100% from 2030

At least 40% reusable within a re-use system, and 100% between own or linked sites and to businesses in the same EU country (Art. 29).

Reusable means a system too

A crate only counts as reusable if it meets the design criteria of Art. 11 and circulates in a system with rules, an operator, a return incentive and reconditioning (Arts. 26–27, Annex VI).

Prove it, don’t promise it

A re-use system must be able to report rotations, rejects, returns, and units added and retired. From 2030 you report every year (Art. 31).

Not everything is settled

The calculation method, the minimum number of rotations and the label with QR code are still to come. Whoever measures now will have the figures.

The targets for transport packaging

From 1 January 2030, or 18 months after the official calculation method if that comes later (Art. 30(4)).

100%

Transport between your own sites, or those of linked and partner enterprises, within the EU

from 2030 · Art. 29(2)

100%

Delivery to another business in the same EU country. For Dutch B2B deliveries that is everything

from 2030 · Art. 29(3)

40%

All other use within the EU, summed across all packaging formats

from 2030 · Art. 29(1)

70%

An aim: a best-efforts duty, not a hard requirement

2040 · Art. 29(1)

Who has to do what.

One company can hold several roles at once. The role decides the duties.

User

Anyone who uses crates, pallets, boxes, trays or pails to transport products within the EU.

Take part in a re-use system and have units reconditioned (Art. 27). Be able to name, for 10 years, who supplied your packaging and whom you supplied (Art. 22). From 2030, meet the targets and report yearly (Arts. 29–31).

Manufacturer

Whoever makes the packaging, or has it made under their own name, brand or design. A client with its logo on the crates is therefore a manufacturer.

Draw up a declaration of conformity and technical documentation, keep them 10 years, and hand them over within 10 days on request (Arts. 15, 39; Annexes VII–VIII).

Producer

Whoever first makes the packaging available in a country, reusable transport packaging included.

Register and file yearly under extended producer responsibility (Arts. 44–45). In the Netherlands this runs through Verpact.

System operator

Whoever runs a re-use system: a pool, a rental company, or the company itself in its own closed loop.

The rules, the checks on reuse and the reporting of Annex VI. For pool-branded packaging the operator is also the manufacturer.

Which packaging counts towards the targets

Pallets · Foldable plastic boxes · Boxes · Trays · Plastic crates · IBCs · Pails · Drums · Canisters · Pallet wrap and straps

This is the complete list of Art. 29(1); the Commission calls it exhaustive. Sea, road, rail and air containers are not packaging.

Roll containers, Danish trolleys and dollies are not on that list. Whether they count towards the reuse targets has not been decided. The crates, trays, pails and pallets that ride on them do count. For the Dutch packaging fee, a roll container already counts as packaging: an exempt "logistics aid".

Dangerous goods. Packaging for transport under the ADR rules (Art. 29(4)(a)).

Custom packaging for large machinery. Packaging designed specifically for large machinery and equipment, with documentation proving it (Art. 29(4)(b)).

Flexible, in contact with food. Flexible packaging in direct contact with food or feed (Art. 29(4)(c)).

Cardboard boxes. Do not count towards the targets (Art. 29(4)(d)).

Pallet wrap and straps. Exempt from the 100% rule (Delegated Decision (EU) 2026/429).

Micro-enterprises. Fewer than 10 staff, at most €2m turnover or balance sheet, and at most 1,000 kg of packaging a year. Both conditions (Art. 29(13)).

What you must be able to show.

There is no official form for the reuse report yet. These are the documents the law names, and who must hold them.

EU declaration of conformity

One declaration per packaging type, following the Annex VIII model: identification (type, batch or serial number), the manufacturer’s name and address, the statement that Arts. 5–12 are met, the standards used, place, date and signature. Updated whenever new rules kick in. No CE mark, no notified body.

Who: Manufacturer · Keep: 10 years · Art. 39, Annex VIII

Technical documentation

Description and use, design and materials, specifications used, how reusability and recyclability were assessed, test reports. For reusable packaging also the description of the re-use system, with written confirmations from its participants.

Who: Manufacturer · Keep: 10 years · hand over within 10 days · Arts. 15, 26(2), Annex VII

Proof of the re-use system

Taking part in a system that meets Annex VI: a pool or rental contract, or your own system, the collection points, the reconditioning records, and the figures on rotations, rejects and returns.

Who: User · Keep: ongoing · Art. 27, Annex VI

Suppliers and customers

On request, name who supplied your reusable packaging and whom you supplied.

Who: Everyone in the chain · Keep: 10 years · Art. 22

Annual reuse report

Per calendar year: reusable versus other units, per target and per flow (own sites, domestic B2B, other). The format and calculation method are still to be set.

Who: User · Keep: first on 2030, by 30 June 2031 · Arts. 30–31

What an inspector can ask for.

What	From whom	Basis
Technical documentation and declaration of conformity, digital, within 10 days	Manufacturer, importer	Arts. 15(10), 18(8)
Who supplied your packaging and whom you supplied	Everyone in the chain	Art. 22
Proof of taking part in a re-use system, reconditioning and returns to collection points	User	Art. 27; Art. 62(1)(h)
The annual report and the calculation behind it (from the 2030 figures)	User	Arts. 30–31; Art. 62(1)(k)
The producer’s registration number	Producer; distributors check it	Art. 44; Art. 19(2)
A working QR code or data carrier (once Art. 12(2) applies)	Manufacturer	Art. 12; Art. 62(1)(c)

What a re-use system must have

Annex VI, Part A: for every system in which reusable packaging circulates.

Clear governance: the roles, the ownership and any transfer of ownership
A system operator that checks the reuse works properly
Rules every participant accepts: allowed types, use, reconditioning, collection, storage, filling and loading
An incentive to bring units back: a deposit, rental with a loss charge, or an exchange rule
Reconditioning before reuse: inspect, remove broken parts, wash, repair, check (Part B)
Reporting rules: rotations per category, rejects, return rate, units added and retired
In a closed loop: reverse logistics, and collection points approved by the operator
Arrangements for producer responsibility for units that become waste

Open systems without an operator, such as the Euro pallet according to the Commission, are exempt from part of this. Closed systems have no transition period.

What Meshwire does, and what it doesn’t.

The law prescribes no technology, only figures. We produce them automatically, per unit, from every handover, trip and return.

Rotations per unit

Every trip from depot to customer and back, counted per crate or trolley. The basis for the minimum rotations once they are set.

Returns and losses

What comes back, what doesn’t, and where it got stuck: with name, date and last position.

Added and retired

New units in the system and retired units, with the reason.

Flows split

Per delivery: own site, domestic customer or abroad. The split that decides whether 100% or 40% applies.

Suppliers and customers, 10 years

Every handover recorded with the counterparty, kept as long as the law asks.

The report

A PPWR report per year, customer or type, as PDF or CSV, or through the API.

What no tracker does for you

Count single-use packaging: that comes from your purchasing or ERP data.
Make packaging reusable: that is a design question (Art. 11).
Replace a re-use system: rules, incentives and reconditioning are agreed, not tracked.
Draw up or sign the declaration of conformity: that is the manufacturer’s job.

Official links, and where to go.

For the text itself, the guidance, registration and returns, and tax relief. Checked on 13 September 2026.

European Union

Dutch government

Registration and returns (Verpact)

Tax relief and subsidies

What is still open.

The minimum number of rotations for reusable packaging: by 12 February 2027 (Art. 11(2)).
The calculation method for the targets, including what an "equivalent unit" is: by 30 June 2027 (Art. 30(3)).
The "reusable" label and QR code: were due by 12 August 2026 (Art. 12(6)).
The format of the producer register: overdue since 12 February 2026 (Art. 44(14)).
The Dutch penalty rules: by 12 February 2027 (Art. 68).
Whether roll containers, Danish trolleys and dollies fall under the Art. 29 targets.
Whether moving crates carrying private household goods are covered.

Start measuring.

Whoever records rotations, returns and losses per unit today will have years of figures by 2030.

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A question about the PPWR?

Karlos knows the regulation, the timeline and the official sources — and links you on.

This page is informational, not legal advice. Sources: Regulation (EU) 2025/40, the European Commission’s guidance and FAQ, KVK, ILT and Verpact. Whether and how the rules apply to your business depends on your situation.