The new EU PPWR regulation will impose strict requirements on industrial packaging from 2026 onwards. Companies must focus on reuse, recyclability and digital traceability in order to remain compliant. This article explains what is changing and how your organisation can prepare.
Summary of this article
The European Packaging and Packaging Waste Regulation (PPWR) will fundamentally change the rules governing packaging in the coming years. While the current directive mainly provided general frameworks, the PPWR imposes specific, binding requirements on the design, use and reuse of packaging throughout the EU. This affects not only consumer packaging, but particularly industrial packaging such as pallets, crates and custom-made transport cases.
For many companies, this means a major transition: packaging must become more reusable, more volume-efficient and more recyclable, while the use of recycled materials will also become mandatory. The consequences are significant, both operationally and financially, but companies that respond to the new rules now can also gain a competitive advantage.
The question is not whether the PPWR will affect your packaging processes, but how quickly you can prepare your organisation for the deadlines that will start to apply from 2026.
The PPWR introduces clear and binding requirements that directly affect industrial packaging. For companies that use pallets, crates, reusable flight cases or custom-made transport cases, these are the most important points to consider.
From 2030, at least 40 per cent of a specified group of transport packaging must be reusable within a formal reuse system. This includes pallets, crates, trays, bins, drums, buckets, IBCs and certain boxes. The 40 per cent is calculated based on the total number of these packaging units used by a company, rather than separately for each packaging type.
This means that packaging must not only be physically strong enough for multiple rotations, but must also demonstrably be used within a reuse system. Companies must therefore have insight into their packaging inventory and the number of use cycles.
For transport between a company’s own sites, affiliated companies and deliveries to companies within the same Member State, these types of packaging must, in principle, be 100 per cent reusable. Pallet wrapping and strapping are exempt from this specific 100 per cent requirement.
The regulation requires packaging volume to be used as efficiently as possible. From 2030, no more than 50 per cent of the total packaging volume of non-reusable transport, grouped and e-commerce packaging may consist of empty space. Reusable packaging that forms part of a reuse system is exempt from this 50 per cent requirement.
This has consequences for the design of interiors, stackability and the use of filling materials.
From 2030, packaging must meet minimum recyclability criteria according to a European grading system: A, B or C. Packaging classified as grade C must be at least 70 per cent recyclable. From 2038, grade C will no longer be permitted, and packaging must achieve at least grade B, corresponding to a minimum recyclability level of 80 per cent.
This requires material choices that facilitate recycling, such as avoiding composite materials or components that are difficult to separate. Exceptions apply to specific packaging, including certain packaging for dangerous goods.
Minimum requirements will apply to the use of post-consumer recycled material in plastic packaging components. The percentages vary according to the type of packaging and will gradually increase towards 2040.
For plastic packaging that does not fall within a specific product category, a minimum of 35 per cent post-consumer recycled plastic will, in principle, apply from 2030. This percentage will be calculated as an annual average per production site. Exceptions apply to packaging for dangerous goods, among other categories.
From 2028, many types of packaging will be required to carry a uniform European material label. Regular transport packaging is exempt from this general labelling requirement. However, the requirement does apply to e-commerce packaging.
From 2029, reusable packaging must be identifiable by a reuse label. Information about the reuse system, collection points and use cycles must also be made available through a QR code or another digital data carrier. This does not mean that every packaging unit must be continuously tracked in real time, but companies must be able to demonstrate its use and reuse.
The European Commission is still developing the precise format of the labels and digital data carriers. As a result, the practical effective date of these requirements may still be postponed.
The PPWR will be introduced in stages. For industrial packaging, the requirements relating to reuse, recyclability, material use and traceability are particularly relevant. The technical details of several obligations will be established through supplementary European rules.
From this date, manufacturers must be able to demonstrate that their packaging complies with the PPWR requirements applicable at that time.
For industrial packaging, the requirements from 2026 will mainly concern limiting harmful substances and demonstrating that packaging is safe and suitable for its intended use. If packaging is marketed as reusable, it must genuinely be suitable for repeated use, emptying, cleaning, refilling and, where necessary, repair.
The manufacturer must substantiate this through technical documentation and an EU declaration of conformity. The specific requirements relating to recyclability grades, minimum recycled plastic content, empty space and reuse percentages will mainly apply from 2030.
Many types of packaging will be required to carry a European label clearly indicating which materials the packaging contains and how they should be separated.
The general material labelling requirement does not apply to regular transport packaging. It does, however, apply to e-commerce packaging. The exact format and definitive practical effective date will still be established in European implementing rules.
Reusable packaging must be clearly identifiable as reusable. In addition, information about matters such as the reuse system, collection points and the number of use cycles must be made available through a QR code or another digital data carrier.
The digital data carrier must help companies and users determine how the packaging can be reused and how many use cycles it has completed. Continuous real-time location tracking of every packaging unit is not mandatory.
From 2030, the requirements for industrial packaging become specific:
Packaging must be designed for recycling and achieve at least recyclability grade C. This means that at least 70 per cent of the packaging must be recyclable according to the European methodology.
For most other plastic packaging, a minimum of 35 per cent post-consumer recycled plastic will apply, calculated as an annual average per production site. Exceptions apply, including for packaging for dangerous goods.
At least 40 per cent of the total number of designated transport packaging units used by a company must be reusable and deployed within a reuse system. This includes pallets, crates, trays, bins, IBCs, drums, buckets and certain boxes.
For transport between a company’s own sites, affiliated companies and deliveries to companies within the same Member State, these types of packaging must, in principle, be 100 per cent reusable. Pallet wrapping and strapping are exempt from this specific 100 per cent obligation.
Packaging must be designed to be as light and compact as possible without compromising protection or functionality. For non-reusable transport, grouped and e-commerce packaging, no more than 50 per cent of the volume may consist of empty space. Reusable packaging within a reuse system is exempt from this requirement.
From 2035, it will no longer be sufficient for packaging to be technically recyclable. It must also be collected, sorted and recycled on a large scale within Europe in practice.
From 2038, packaging with grade C may no longer be placed on the European market. Only packaging with grade A or B will remain permitted. This means a minimum recyclability score of 80 per cent.
This obligation applies to packaging covered by the PPWR recyclability requirements. Exceptions apply to a number of specific applications.
For 2040, the PPWR specifies a target of 70 per cent reusable designated transport packaging. For the time being, this is an ambitious target rather than a binding obligation like the 40 per cent standard for 2030.
The PPWR not only imposes technical and design requirements, but also creates a considerable administrative burden. Companies must be able to demonstrate how much packaging they use, what proportion is reusable and how many use cycles the packaging completes. Reusable packaging must be included in a reuse system and, from 2029, provided with the required information. Producers will also face registration, documentation and reporting obligations. For many companies, this means adding a new layer of compliance management to their day-to-day operations.
As a packaging partner, we take responsibility for the complete management and coordination of packaging. We ensure that packaging is used optimally throughout its entire life cycle, from design and use to reuse, cleaning, repair and replacement. Because Faes operates independently, we work with multiple manufacturers and partners. This allows us to provide our customers with the best price-quality ratio, the right expertise and the most sustainable solution at all times.
Operational Benefits
With Faes as your packaging partner, you have access to real-time data on rotations, reuse rates and material flows. This makes it easier to comply with laws and regulations while also providing insights that can be used to optimise logistics and inventory management. Maintenance, cleaning and replacement are coordinated by Faes and carried out through the most suitable partners. This allows us to guarantee continuity with a minimal packaging inventory and maximum availability.
We also take full responsibility for the administrative process. This includes integrated invoicing for storage, transport and value-added services such as triage and cleaning, combined with transparent reporting and clear agreements. This saves time, prevents delays and creates predictability throughout the process.
Strategic Advantage
By outsourcing packaging management to Faes, you reduce internal pressure and minimise the risk of fines or non-compliance. Our system is designed around the requirements of the PPWR and aligns seamlessly with sustainability and ESG objectives.
The major advantage is that Faes looks beyond cost savings alone. By managing packaging more intelligently and circularly, we create value throughout the entire supply chain. Companies benefit from a scalable and proven model in which reuse, material optimisation and transparent reporting are embedded, while control always remains with the customer.
The PPWR marks a turning point in the way companies design, deploy and manage packaging. For industrial packaging, this means stricter requirements, higher reuse targets and more administrative obligations. Companies that wait until the first deadlines approach risk costly adjustments, compliance issues and missed opportunities.
By acting now and working with an independent packaging partner, the transition to future-proof packaging management becomes not only achievable, but also strategically advantageous. As the coordinating partner, Faes takes responsibility for the complete management and coordination of packaging, including tracking, reporting, maintenance and cooperation with the most suitable manufacturers and partners. This helps you remain compliant with the PPWR, achieve cost savings and logistical efficiency, and strengthen your sustainability and ESG performance at the same time.
The time to act is now. Companies that take the first steps today will not face a challenge in 2026, but will have a head start.
Thijs Canjels is Business Innovation Manager at Faes and specializes in packaging management and supply chain optimization. In his blogs, he shares insights on efficiency improvements, cost savings and the strategic role of packaging in modern supply chains.
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