The European Commission has adopted a delegated act under the PPWR Regulation introducing an exemption from the reusability requirements for pallet wrapping films and pallet straps.
As we informed you in December (HERE), the Commission responded to concerns raised by industry stakeholders, opened the possibility for an exemption from the reusability obligation, held discussions with interested parties, launched a public consultation, and in February 2026 adopted Commission Delegated Decision (EU) 2026/429 of 25 February 2026 supplementing Regulation (EU) 2025/40 of the European Parliament and of the Council. The decision exempts certain economic operators using pallet wrapping films and straps from the requirement to achieve a 100% reuse rate for these packaging formats. The decision therefore supplements the Packaging and Packaging Waste Regulation (PPWR).
The Decision was published in the Official Journal of the European Union on 6 May 2026 and will enter into force on the twentieth day following its publication, i.e. on 26 May 2026.
What is changing?
The delegated act modifies the requirements laid down in Article 29 of the PPWR, which introduce mandatory reusability targets for certain packaging formats.
Under the PPWR, from 1 January 2030 specified transport packaging and sales packaging used for the transport of products must be 100% reusable when used for transport:
- within the same company (between facilities located in the EU),
- between partner companies within the EU,
- within a single Member State.
These obligations originally also applied to pallet wrapping films and straps used to stabilize and protect goods placed on pallets during transport. Following a more detailed assessment, the Commission acknowledged that introducing reusability requirements for these packaging formats would require disproportionate investments and substantial modifications to existing logistics systems. It therefore decided to exempt them from the obligation.
However, pallet films and straps are not excluded from the overall 40% reusability target under Article 29(1) PPWR. According to the recital, economic operators may achieve this target by balancing packaging formats with low reuse rates through the use of formats with high reuse rates.
What remains unchanged?
The obligations regarding 40% and 100% reusability remain in force for the other defined transport and sales packaging formats used for transporting goods, including goods distributed through e-commerce, such as pallets, foldable plastic boxes, plastic crates, trays, buckets, drums, canisters, and similar packaging formats.
The PPWR also continues to provide exemptions from both the 100% and 40% reusability requirements for packaging:
- used for the transport of dangerous goods,
- used for large equipment requiring specially adapted packaging,
- flexible packaging formats in direct contact with food or feed, and
- cardboard boxes.
A link to the delegated decision can be found HERE.
