Reusable pallets and the PPWR: obligations, exemptions, deadlines
In briefRegulation (EU) 2025/40 applies from 12 August 2026 and, from 1 January 2030, requires at least 40% of the pallets used for transport to be reusable within a re-use system. Between sites of the same company or group, and for deliveries to another business in the same Member State, the share rises to 100%, unless an exemption applies.
This page is not legal advice. It summarises the text of Regulation (EU) 2025/40 as published on EUR-Lex; for business decisions, check the official text and the delegated acts in force with your adviser.
The PPWR is the first EU regulation to require a fixed share of reusable pallets. Here you will find the dates, shares, exemptions and what makes a pallet 'reusable' in law, with references to the articles.
The dates at a glance
| Date | What happens | Reference |
|---|---|---|
| 11 February 2025 | the regulation enters into force | Art. 71 [1] |
| 12 August 2026 | the regulation applies | Art. 71 [1] |
| 26 May 2026 | exemption of film and straps from the 100% obligation in force | Decision (EU) 2026/429 [2] |
| by 12 February 2027 | delegated act on the minimum number of rotations | Art. 11(2) [1] |
| 1 January 2030 | 40% target and 100% obligations for pallets | Art. 29 [1] |
| 1 January 2030 | 35% post-consumer recycled content in the plastic part of non-contact-sensitive packaging | Art. 7(1)(d) [1] |
| 1 January 2040 | aim of 70% reusable; 65% recycled content | Art. 29(1), Art. 7(2)(d) [1] |
What Article 29 says about pallets
Article 29 names pallets explicitly, together with foldable plastic boxes, boxes, trays, IBCs, pails, drums, canisters, pallet wrappings and straps [1]. There are three levels of obligation, all from 1 January 2030.
General rule, paragraph 1: anyone who uses this packaging to transport products within the EU must ensure that at least 40% of the total is reusable within a re-use system. From 2040 they must aim to reach 70% [1]. The share is an overall one: a format with a low reuse rate can be offset by one with a high rate [2].
Internal flows, paragraph 2: between sites of the same company, or between your own site and that of a linked or partner company, all such packaging must be reusable within a re-use system [1].
Deliveries within the same country, paragraph 3: when the packaging is used to deliver products to another economic operator in the same Member State, the same 100% obligation applies [1].
The targets are calculated over a calendar year [1]. The calculation method will be set by a Commission implementing act, due by 30 June 2027; the obligation to demonstrate that the targets have been met starts on 1 January 2030 or 18 months after that act enters into force, whichever is later [1].
Who is exempt
Paragraph 4 excludes from the obligations in paragraphs 1, 2 and 3 packaging [1]:
- used for the transport of dangerous goods under Directive 2008/68/EC;
- for large machinery, equipment and products, where the packaging is custom-designed for the individual customer;
- in flexible formats in direct contact with food, feed or food ingredients;
- in the form of cardboard boxes.
Other exemptions in the same article [1]:
- a micro-enterprise that makes available no more than 1,000 kg of packaging in a Member State in a calendar year is exempt for that year;
- a Member State may exempt operators for 5 years, renewable, if it exceeds the recycling targets by 5 percentage points, cuts packaging waste per capita by at least 3% by 2028 compared with 2018, and the operator has a business plan for waste prevention and recycling;
- the Commission may add sector-specific exemptions through delegated acts.
Stretch film and straps
The Commission has used this power once so far. Delegated Decision (EU) 2026/429 of 25 February 2026, published on 6 May 2026, exempts users of pallet wrappings and straps from the 100% obligations in paragraphs 2 and 3 [2]. According to EUR-Lex it has been in force since 26 May 2026.
The exemption is narrow. Film and straps remain among the Article 29 formats and count towards the general 40% target; the pallet under the film is not exempt [2].
What makes a pallet 'reusable'
Durability alone is not enough. Article 11 lists the conditions for packaging to count as reusable; among them [1]:
- it is conceived, designed and placed on the market to be reused several times;
- it is designed for the highest possible number of rotations under normally foreseeable conditions of use;
- it can be emptied or unloaded without damage that prevents its reuse;
- it can be reconditioned while keeping its function;
- it allows labelling and tracking;
- at the end of its life it meets the recyclability requirements of Article 6.
The minimum number of rotations will be set by a Commission delegated act by 12 February 2027 [1]. Until then the law gives no figure.
You also need a re-use system. Article 3 defines it as the organisational, technical or financial arrangements, with incentives, that make closed-loop or open-loop reuse possible and ensure that packaging is collected for reuse [1]. A pallet that lasts for years but leaves and never comes back does not count: what counts is the return loop, your own or a rental provider's.
Plastic, wood and recycled content
The PPWR does not pick a material. A wooden pallet in a rental pool can meet Article 29 just as well as a plastic pallet in a closed loop. The same goes for the environment: the LCA study by Anil et al. gives wood a carbon footprint per trip 71.8-80.3% lower, and on a basis of 100,000 trips the gap widens [3]. The comparison is in plastic or wooden pallets.
Plastic pallets face a second requirement. Article 7 requires post-consumer recycled content in the plastic part of packaging: for non-contact-sensitive formats such as pallets, 35% from 2030 and 65% from 2040, calculated as an average per manufacturing plant and per year, subject to the exemptions and derogations in the same article [1]. This applies first of all to whoever makes the pallet and places it on the market, but as a buyer it is worth asking for the recycled percentage now. The limits on recycled material for food use are in hygienic and food-grade pallets.
What to do now if you ship on pallets
- Count your pallets. How many you use in a year, of what type, how many come back and how many leave as one-way.
- Split your flows into three groups: between your own or group sites, to customers in the same Member State, to customers abroad. The first two must reach 100%, the third falls under the 40%.
- Check the exemptions: dangerous goods, custom-designed packaging, micro-enterprise.
- Choose the re-use system: your own loop, returnable pallets with a deposit, a rental pool. The cost comparison is in renting or buying pallets; for re-use loops, CONAI (the Italian packaging recovery consortium) offers reduced-fee schemes, explained in CONAI and plastic tax.
- Measure your losses. A low return rate makes reuse expensive and may not be enough to meet the target.
- Ask your pallet suppliers for the technical information the regulation calls for: reusability under Article 11, recyclability and recycled content.
- Follow the delegated acts: minimum number of rotations by February 2027 and any new exemptions.
For industrial reels and rolls, where the reel pallet often travels between plants of the same group, paragraph 2 is the first thing to look at. See reel pallets.
Frequently asked questions
When does the PPWR apply?
Regulation (EU) 2025/40 on packaging applies from 12 August 2026, as laid down in Article 71. The reuse targets for pallets and other transport packaging, however, start on 1 January 2030.
Does the PPWR require plastic pallets?
No. Article 29 requires reusable pallets within a re-use system, in any material. A wooden pallet managed in a return or rental loop counts just as much as a plastic one.
How many pallets must be reusable from 2030?
At least 40% of the total transport packaging listed in Article 29, which includes pallets, calculated over a calendar year. From 2040 the operator must aim to reach 70%. For transport between sites of the same company or of linked companies, and for deliveries to another operator in the same Member State, the share is 100%.
Do stretch film and straps have to be reusable?
Delegated Decision (EU) 2026/429, now in force, exempts users of pallet wrappings and straps from the 100% obligation in Article 29(2) and (3). Film and straps still count, however, towards the general 40% target.
Who is exempt from the reuse targets?
Article 29 excludes the transport of dangerous goods, custom-designed packaging for large machinery and equipment, flexible packaging in direct contact with food and feed, and cardboard boxes. A micro-enterprise that makes available no more than 1,000 kg of packaging is also exempt, year by year.
How many rotations must a pallet make to count as reusable?
The regulation does not yet set a number. Article 11 requires packaging to be designed for the highest possible number of rotations and tasks the Commission with a delegated act, due by 12 February 2027, that will set the minimum number for the most common formats.
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