PPWR puts pallets under stricter reuse rules

The PPWR, formally known as Regulation (EU) 2025/40 on packaging and packaging waste, has applied across the European Union since 12 August 2026. It covers the entire packaging lifecycle, with the aim of reducing waste and increasing reuse.

The rules also apply to transport packaging. The regulation specifically includes pallets, collapsible plastic crates, boxes, trays, crates, IBC containers, buckets, drums and jerry cans.

As a result, pallet management is becoming more than an operational and cost issue. Companies will need to understand how these assets move through the supply chain, who controls them and whether they are genuinely part of a functioning reuse system.

At least 40% of transport packaging must be reusable from 2030

The first major deadline is 1 January 2030. From that date, businesses using certain types of transport packaging in the EU will have to ensure that at least 40% of it is reusable packaging forming part of a reuse system.

Pallets are included in this target.

The requirements go further. The PPWR sets stricter rules for certain flows taking place within one company, between companies in the same group or within a single member state.

From 2030, transport packaging moving between sites belonging to the same company or between related companies must be reusable and used within a reuse system. The same principle applies to deliveries made to another company within one member state.

In these cases, the packaging must be suitable for repeated use and form part of an established reuse system.

However, not every load-securing product is subject to identical requirements. In 2026, the Commission decided, among other measures, to exclude films and straps used to stabilise pallet loads from part of the 100% reuse requirement, citing potentially disproportionate compliance costs.

The target rises to 70% in 2040

The PPWR sets a second milestone. From 1 January 2040, businesses are expected to work towards using reusable packaging within a reuse system for at least 70% of the transport packaging covered by the rules.

The 40% threshold introduced for 2030 is therefore only an intermediate step in the changes planned for transport packaging.

The return of a pallet is not enough

The regulation does not define reuse simply as using the same asset more than once. It requires a functioning reuse system. Companies using reusable packaging must participate in such a system and ensure that it meets the conditions set out in the regulation. Before packaging is put back into service, it must be properly prepared for its next use.

This places greater importance on information showing how packaging is used, returned, repaired and put back into circulation.

For businesses, that means closer oversight of transport assets and the processes supporting their return and reuse. Companies will need data demonstrating that a pallet or another type of transport packaging genuinely remains within a reuse system, rather than merely being returned to its owner from time to time.

Pallet owners will need better control over asset flows

In many businesses, a pallet leaves its owner’s direct control almost as soon as a shipment departs. It may then pass between manufacturing sites, carriers, logistics operators, warehouses, distribution centres and customers.

Until now, the main challenge was often recovering the pallet or settling its value. The new rules make broader oversight of the entire process more important. Companies will need to focus on which packaging assets are in circulation, whether they are being used within a reuse system and how they move through each stage of the supply chain.

For businesses using their own assets, this may require a review of existing recording, identification and return processes. In complex supply chains, it will be particularly important to determine where pallets are located and who is responsible for their next movement.

This does not mean that the PPWR requires every company to track every individual pallet in real time. The key requirement is to demonstrate compliance with the reuse rules and show that an appropriate system is operating.

Pallet pooling could become more important

Pallet pooling is one way to manage reusable assets centrally. Under this model, users do not have to own the pallets they use. The pool operator manages their circulation, collection, inspections, repairs and return to service. The regulation also allows responsibility for operating one or more shared reuse systems to be assigned to a third party.

CHEP, a pallet-pooling operator, has highlighted the relevance of this model under the new rules. Centralised asset management can make it easier to organise returns and repairs and to collect data about how pallets move through the supply chain.

That does not make pooling a legally required solution. The PPWR defines the targets and conditions for reuse, while businesses remain free to organise their packaging flows in different ways.

Logistics companies will need to look beyond pallets

The PPWR also applies to other packaging used in warehousing and transport. The regulation covers crates, containers, drums, jerry cans and other packaging used to move goods. Companies will therefore need to take a broader view of transport-packaging management than simply monitoring EUR pallets or their own warehouse assets.

This will be especially relevant to businesses managing large numbers of packaging units moving between multiple warehouses, distribution centres and trading partners. The PPWR therefore makes transport-packaging management a matter not only of day-to-day operations, but also of compliance, data management and supply-chain governance.

The main reuse targets begin in 2030, with a more ambitious level planned for 2040. Companies have several years to assess whether their current systems for circulating pallets and other transport assets can do more than simply recover them — and whether they can demonstrate that those assets genuinely operate as reusable packaging within a system that complies with the PPWR.