Packaging and Packaging Waste Regulation (PPWR)
How our products meet or exceed regulatory demands
- Sustainability
- PPWR
What PPWR means for reusable transport packaging
The Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, is now in force. It entered into force on 11 February 2025 and generally applies from 12 August 2026. The focus has therefore moved from negotiating the legislation to implementing its requirements across the EU.
PPWR covers packaging and packaging waste regardless of material or origin and introduces requirements across the packaging life cycle, including packaging design, recyclability, recycled content, waste prevention and reuse. Its impact on an individual company depends on factors such as the packaging format, transport flow, economic operator role and applicable exemptions.
For companies using transport packaging, reusable systems can play an important role in meeting relevant PPWR reuse and circularity requirements. However, using reusable packaging does not by itself establish full PPWR compliance.
PPWR is moving into the implementation phase
Regulation (EU) 2025/40 establishes the legal framework, but its implementation continues through European Commission guidance, delegated and implementing acts and relevant requirements at Member State level. The Commission published PPWR implementation guidance in 2026 and continues to clarify how specific provisions apply in practice.
Key milestones include:
2025 - PPWR entered into force
11 February 2025 - PPWR entered into force.
2026 - PPWR provisions generally begin to apply
12 August 2026 - Most PPWR provisions generally begin to apply.
2030 - Reuse requirements take effect
1 January 2030 - Major reuse requirements for specified transport packaging formats take effect. Recyclability performance requirements based on design-for-recycling criteria also become relevant.
2035 - Recyclability assessment
2035 - Recyclability assessment increasingly includes whether packaging is recycled at scale.
2040 - Further PPWR milestones apply
2040 - Further PPWR milestones apply. For transport and sales packaging covered by the Article 29(1) target, economic operators are to endeavour to reach at least 70% reusable packaging within a re-use system. Further recycled-content and packaging-waste reduction milestones also apply.
The 2030 transport-packaging target is generally 40% for the specified formats covered by Article 29(1), while the 2040 70% figure is an indicative or aspirational target rather than the same type of binding requirement.
What are the PPWR reuse requirements for transport packaging?
From 1 January 2030, economic operators using specified transport packaging or sales packaging for transporting products within the EU must generally ensure that at least 40% of that packaging in total is reusable packaging within a re-use system. Formats covered include pallets, foldable plastic boxes, boxes, trays, plastic crates and several other transport packaging formats.
Some transport flows are subject to stronger requirements. Packaging used between different sites of the same undertaking, or between an undertaking and linked or partner enterprises, is generally required to be reusable within a re-use system. A similarly strong requirement applies to specified packaging used to deliver products to another economic operator within the same Member State. In practical terms, these provisions generally amount to 100% reuse for the affected flows.
These requirements should not be treated as a universal percentage for every B2B packaging application. Applicable obligations depend on the packaging format, transport flow, economic operator and relevant exclusions or exemptions. Secondary legislation can also affect how individual requirements apply; for example, the Commission adopted an exemption in February 2026 concerning pallet wrapping and straps and the 100% reuse requirements.
How can PPWR affect your company?
PPWR does not simply require every company to replace all disposable transport packaging with returnable packaging.
The first step is to understand which packaging and transport flows fall within the relevant PPWR provisions. Companies may also have different responsibilities depending on whether they act as a manufacturer, producer, importer, distributor or another economic operator.
For transport packaging in particular, it is useful to examine the packaging formats being used, where packaging moves between sites and companies, which reuse requirements may apply, whether an appropriate re-use system exists and what additional design, recyclability, documentation or other requirements need to be considered.
Because these factors vary between companies and applications, PPWR preparation requires a situation-specific assessment rather than a single packaging solution
Who is the manufacturer or producer under PPWR?
Under PPWR, the roles of manufacturer, producer and reusable transport packaging supplier can vary depending on how packaging is designed, branded and placed on the EU market. Use the RCTP interactive tool to explore which role may apply to your scenario and understand the related responsibilities.
Download our PPWR Guide
Get an overview of PPWR and its relevance to reusable transport packaging.
Download the PPWR GuideHow can reusable transport packaging support PPWR compliance?
Reusable transport packaging can support important PPWR objectives, particularly where the Regulation establishes reuse requirements for transport packaging and encourages packaging waste prevention.
However, reusable does not automatically mean PPWR compliant. Depending on the packaging and application, relevant requirements can also concern design, recyclability, participation in a re-use system, labelling, technical documentation and the responsibilities assigned to individual economic operators.
The practical question is therefore not simply whether packaging is reusable, but whether the complete packaging solution and the way it is placed on the market and used meet the requirements that apply to that particular situation.
Reuse, design for recycling and recycled material at Utz
Utz develops and manufactures reusable plastic logistics solutions, including containers, pallets, trays, component holders and customer-specific load carriers. Utz products are designed for repeated use, while design for recycling and material recovery form part of the company's circular-economy approach.
Utz Industrial Compound (UIC®) provides recycled-material options for suitable products and projects. UIC® does not apply to the entire Utz portfolio, and material selection depends on the requirements of the particular product and application.
These characteristics can support customers working towards PPWR reuse and circularity requirements, but PPWR compliance must always be considered in the context of the specific packaging, application and economic operator.
PPWR applies across packaging materials
PPWR covers packaging regardless of the material from which it is made. Specific requirements, targets and exemptions can nevertheless differ according to packaging type, format, use and material.
Utz believes that differences in how certain PPWR provisions apply across packaging materials may affect material neutrality. This is an Utz position rather than a general description of the Regulation.
Preparing your transport packaging for PPWR
For many companies, PPWR creates a reason to review existing transport packaging and determine where reusable systems are required or make operational sense.
Utz can support this packaging work by developing standard and customer-specific reusable logistics solutions around the requirements of the product and logistics process. Relevant considerations can include product protection, handling, return flows, automation interfaces, identification and appropriate material choices. Utz's approved product information supports this positioning without implying that one packaging format provides an automatic compliance solution.
Need help preparing your transport packaging for PPWR?
Explore how reusable transport packaging can support your PPWR strategy and your wider logistics requirements.
Discuss your packaging with UtzFrequently Asked Questions
What is the PPWR?
The Packaging and Packaging Waste Regulation is Regulation (EU) 2025/40. It establishes EU-wide requirements covering packaging throughout its life cycle, including waste prevention, recyclability, recycled content and reuse. It entered into force on 11 February 2025 and generally applies from 12 August 2026.
Does PPWR require all B2B transport packaging to be reusable?
No. PPWR establishes reuse requirements for specified packaging formats and transport flows. From 2030, a 40% reuse target generally applies to the transport and sales packaging formats covered by Article 29(1), while certain intra-company, linked-enterprise and domestic B2B flows are subject to stronger requirements. Exclusions and exemptions also need to be considered.
Is reusable transport packaging automatically compliant with PPWR?
No. Reusability can support compliance with relevant PPWR reuse requirements, but packaging can also be subject to requirements concerning design, recyclability, re-use systems, documentation, labelling and other criteria. Responsibilities also depend on the economic operator involved.
Is paper or board packaging excluded from PPWR?
No. PPWR covers packaging and packaging waste regardless of material. Individual provisions, targets and exemptions can nevertheless apply differently to different packaging types and materials.
Who is the manufacturer or producer of reusable transport packaging?
That depends on the particular supply-chain scenario. PPWR defines manufacturer and producer for different purposes, and factors such as branding, design responsibility and how packaging is first made available can affect the applicable role. The PPWR Producer & Manufacturer Tool can help users explore the roles that may apply, but it does not provide a legally binding compliance determination.
How can Utz support a PPWR packaging strategy?
Utz can help companies explore reusable transport packaging that fits their products and logistics processes. This can include standard containers, pallets and trays as well as customer-specific load carriers and solutions designed around handling, automation and circular logistics requirements.
Do you have questions about the PPWR?
Complete the contact form below. Our team will be happy to help you understand what the new requirements may mean for your packaging and supply chain.
Any other questions?
Write to us or call us! Our qualified employees are always available to answer your questions.
Georg Utz AG
Augraben 2-4
5620 Bremgarten, AG
Switzerland