PPWR reuse obligation: What companies need to know now

Basics: What does the PPWR reuse obligation mean?

PPWR stands for Packaging and Packaging Waste Regulation. In German, this is the EU regulation on packaging and packaging waste. Unlike an EU directive, a regulation generally applies directly in the Member States. The PPWR gradually replaces the previous EU framework for packaging and packaging waste.

The PPWR reuse obligation describes requirements under which certain packaging must be reusable or used within a reuse system. This does not mean that every package must immediately be replaced by reusable packaging. The decisive factors are the packaging type, field of use, timing and the specific quota.

Important terms at a glance

Reusable packaging

Reusable packaging is packaging designed to be used multiple times. It must therefore be robust enough to withstand several cycles and be part of a system that enables return, cleaning, inspection and reuse.

PPWR reuse quota

A reuse quota specifies what proportion of certain packaging must be reusable and used within a reuse system. The quota does not apply to all packaging across the board, but to specific packaging categories.

Company placing packaging on the market

Put simply, a company placing packaging on the market is a company that makes packaging available on the market for the first time. In a B2B context, this may be a manufacturer, importer, retailer or shipping company. The exact role depends on who makes the packaging available and in which market it is used.

Transport packaging

Transport packaging protects goods during transport and facilitates storage, handling and delivery. It includes, for example, pallets, crates, trays, drums, canisters, layer pads or certain grouped packaging used for transport. PPWR transport packaging is particularly in focus under the reuse requirements.

We advise you on all matters relating to the VerpackDG/PPWR:

Legal framework: Reuse under the EU Packaging Regulation

The PPWR was published as Regulation (EU) 2025/40. It entered into force on 11 February 2025 and, following an 18-month transition period, is expected to apply predominantly from 12 August 2026.

Important for companies: The reuse requirements will not all apply at the same time. The PPWR provides for phased obligations. Some requirements concerning the general organisation of reuse systems will apply from 2026. Further reuse quotas will apply later, particularly from 2030 onwards.

Under Article 29 of the PPWR, reuse targets are provided for certain packaging types. For certain transport packaging, a quota of at least 40% is specified from 2030, with a higher target envisaged for 2040. Stricter reuse requirements may become relevant for certain intra-company or domestic B2B transport operations. At the same time, there are exemptions and special rules, for example for certain strapping or pallet wrapping, whose precise application should be reviewed carefully.

It is therefore important that companies do not prematurely assume that every type of transport packaging will automatically be subject to a reuse obligation from 2026. The correct view is: The PPWR lays the foundation for more reuse. However, the specific obligations depend on the packaging type, use, market role, supply relationship and timing.

Which companies are particularly affected?

The EU Packaging Regulation’s reuse requirements primarily affect companies that regularly use packaging in B2B supply chains. This is particularly relevant for:

• Manufacturers that supply goods to retailers, processors or other businesses

• Importers bringing packaged products into the EU

• Wholesalers and distributors

• Industrial companies with regular goods flows

• E-commerce companies shipping to business customers

• Logistics companies, fulfilment service providers and warehouse operators

• Companies with pool systems, pallet loops or reusable containers

The focus is often on packaging that does not become waste at private end consumers but circulates in professional supply chains. This includes pallets, plastic crates, reusable boxes, IBC containers, drums, trays and other durable load carriers and transport aids.

Companies that currently use single-use transport packaging should also assess whether reusable packaging will become advisable or required under the PPWR. The change affects more than simply purchasing new packaging. It also changes processes in warehousing, shipping, returns, cleaning, quality inspection and documentation.

Which packaging types are in focus?

The PPWR distinguishes between different packaging types. The following categories are particularly relevant to the reuse obligation and reuse quota:

Transport packaging

Transport packaging protects products on their way between companies. It includes, for example, pallets, crates, boxes, drums, canisters, trays or packaging used to stabilise goods during transport. PPWR transport packaging is particularly important because the Regulation aims to strengthen reuse in commercial supply chains.

Sales packaging in B2B use

Sales packaging may also be relevant where it is used in certain commercial settings. Sales packaging is packaging that is typically directly associated with a product and delivers it to the user or customer. In B2B contexts, the classification may be challenging in individual cases.

Grouped packaging and shipping packaging

Grouped packaging combines several units. Shipping packaging is used to ship a product. Depending on their use, these packaging types may also be affected by reuse requirements or other PPWR obligations. The decisive factor for assessing reuse is whether they fall within a specific category of the Regulation.

Reusable packaging

If companies already use reusable packaging, this is initially positive. However, these packages will need to meet specific requirements in the future. It is not enough to use packaging multiple times. It must also be designed for reuse and integrated into a functioning reuse system.

What does “reusing packaging” mean in practice?

Reusing packaging means more than an occasional second use. The PPWR aims for structured reuse systems. Such a system should ensure that packaging is returned after use, inspected, cleaned or repaired where necessary, and used again.

In practical terms, this means:

• Clear return processes are required.

• Packaging must be identifiable.

• Reuse cycles should be documented.

• Damage must be identified and assessed.

• Responsibilities between suppliers, customers and service providers must be defined.

• Packaging must be suitable for multiple uses.

For example, a robust reusable box that circulates between a manufacturer and a retailer can, under certain conditions, be part of a reuse system. A cardboard box that happens to be used a second time will generally not automatically fulfil this function.

We advise you on all matters relating to the VerpackDG/PPWR:

Practical implementation: Step by step for B2B companies

The PPWR is extensive. A structured start is therefore recommended for meeting the reuse obligation. Companies should not wait until every detailed question has been clarified. Many preparatory measures already make sense today.

1. Record your packaging inventory

First, create an overview of all packaging used or made available by your company. At a minimum, record:

• Packaging type

• Material

• Area of use

• Country of dispatch and country of receipt

• B2B or B2C use

• Single-use or reusable

• Annual quantity

• Relevant sites and business partners

Without this data, it is difficult to assess whether a PPWR reuse quota is relevant.

2. Classify packaging from a legal perspective

Assign each packaging type to a category. Is it transport packaging, sales packaging, grouped packaging or shipping packaging? This classification is crucial because obligations do not apply equally to all types of packaging.

A detailed review is particularly worthwhile for combined packaging solutions. In practice, packaging may fulfil more than one function. In this case, it should be clearly documented which function predominates and which obligation follows from this.

3. Review the company’s role

Clarify whether your company is a manufacturer, importer, retailer, fulfilment service provider, packaging user or another economic operator. The PPWR uses different roles. Obligations may depend on whether you manufacture packaging, first make it available or only use it within your own operations.

For B2B decision-makers, clarifying roles is particularly important because suppliers and customers often make different assumptions. A written alignment is the better approach.

4. Identify affected supply flows

Review where packaging moves within the EU. Recurring deliveries between established business partners, intra-company transport and deliveries within one Member State are particularly relevant. These flows are often better suited to reuse than one-off or frequently changing delivery relationships.

5. Assess suitability for reuse

Not every package is suitable for reuse. Review the following:

• Is the packaging durable enough for multiple cycles?

• Can it be cleaned or repaired?

• Is it sufficiently standardised for return and storage?

• Are there hygiene, technical or safety requirements?

• Is a pool system possible?

• Are customers willing to return packaging?

This assessment combines legal requirements with operational feasibility.

6. Establish or join a reuse system

If reuse is relevant, you need a system. This may be your own take-back system, a joint industry system or an external pooling provider. The decisive factor is that the cycle actually works.

Clearly define:

• Ownership of the packaging

• Return periods

• Deposits or fees

• Cleaning and inspection

• Loss and damage

• Evidence and reporting

7. Prepare data and evidence

Reuse quotas can only be met if quantities and cycles are traceable. Companies should clarify early which data is available from ERP systems, warehouse management, shipping software or service-provider reports.

Important key figures include:

• Number of packaging units used

• Share of reusable packaging

• Number of reuse cycles

• Loss rates

• Repair and sorting-out rates

• Supply flows by country and customer group

8. Involve suppliers and customers

Reuse rarely works in isolation. Engage early with suppliers, customers, logistics partners and packaging manufacturers. Many questions can only be resolved jointly: Who takes packaging back? Who cleans it? Who bears the cost of losses? Who provides data?

Especially in B2B contexts, a well-coordinated process is often more important than the individual packaging itself.

Common mistakes concerning the PPWR reuse obligation

Mistake 1: Confusing reuse with recycling

Recycling means that material is recovered after use. Reuse means that the packaging itself is used again. These are different obligations and strategies.

Mistake 2: Looking only at packaging material

Whether packaging is made of plastic, paper, wood or metal, the material alone does not determine whether the reuse obligation applies. The packaging function, area of use and legal category are important.

Mistake 3: Replacing single-use processes only with more robust packaging

More robust packaging is not yet a reuse system. Without take-back, inspection and redeployment, the practical implementation remains incomplete.

Mistake 4: Involving supply chains too late

Reuse affects procurement, sales, logistics, warehousing and customer service. Companies that only start shortly before the deadline risk process problems, additional costs and data gaps.

Mistake 5: Applying exemptions as a blanket rule

There are exemptions and special rules. However, they should not be applied as a blanket rule. Whether an exemption applies depends on the specific use of the packaging.