PPWR Update: No 100% Reuse Requirement for Pallet Straps and Pallet Wrapping
Source: European Commission
The European Commission has adopted a Delegated Act exempting pallet wrapping and straps from the 100% reuse requirement previously set out by the PPWR. Published on 25 February 2026, this is the first Delegated Act applied under the Packaging and Packaging Waste Regulation.
Key Takeaways
- The PPWR removes the 100% reuse rule for pallet wrapping and straps.
- The exemption applies due to high cost and low operational feasibility.
- Pallet wrapping and straps remain part of transport packaging under PPWR.
- The PPWR 40% reuse target for all packaging stays mandatory.
- The deadline for the PPWR reuse target is 1 January 2030.
- Companies can meet PPWR targets without fully reusing these materials.
- Businesses must review packaging systems to ensure PPWR compliance.
The EU Commission Introduces Exemption For Pallet Wrapping And Straps
According to the PPWR, pallet wrapping and straps used to secure goods during transport were categorized as transport packaging and were therefore subject to specific re-use targets under Article 29. If used during transport within a single company and deliveries between companies in the same Member State, they were originally subject to a 100% reuse target.
Due to stakeholder feedback, the Commission assessed whether this target was operationally and financially viable. The study found that requiring exclusive use of reusable pallet wrapping and straps would impose disproportionate costs on economic operators. The exemption was granted on those grounds.
PPWR 2026 Reuse Rules for Transport Packaging in Europe
| Category | PPWR Requirement (Before) | PPWR Update (2026) | Business Impact | Action Required |
| Pallet Wrapping | High reuse requirements in certain transport scenarios | No 100% reuse requirement | Reduces handling and return complexity | Use partial reuse where viable |
| Pallet Straps | High reuse requirements in controlled transport cases | Exempt from 100% reuse requirement | Cuts operational and recovery costs | Shift to cost-efficient materials |
| Regulatory Basis | Article 29 set reuse obligations for transport packaging | Delegated Act introduces exemption | More flexible compliance approach | Track legal updates closely |
| Cost Feasibility | High cost due to reverse logistics systems | Cost burden reduced | Improves margin control | Reallocate sustainability budget |
| Operational Feasibility | Limited due to damage and recovery constraints | Recognized as not fully feasible | Easier day-to-day operations | Simplify logistics workflows |
| Packaging Scope | Format-level reuse enforcement | Portfolio-level compliance allowed | Less rigid system design | Manage total packaging mix |
| PPWR Overall Reuse Target | 40% reuse requirement for transport and sales packaging | No change | Core sustainability goal remains | Track total reusable share |
| Compliance Strategy | Focus on specific packaging formats | Focus on total packaging system | Simplifies reporting | Audit full packaging portfolio |
The 40% Reuse Target Is Still Non-Negotiable
The exemption does not reduce overall PPWR obligations. From 1 January 2030, economic operators must ensure that at least 40% of transport and sales packaging is reusable. Pallet wrapping and straps remain within this broader category.
Operators can meet the 40% target without achieving full reuse for these two formats specifically. The Commission considers this approach aligned with current technological and financial realities.
With this Delegated Act, the Commission reinforces overarching sustainability objectives while acknowledging operational realities and reducing unnecessary administrative burden for businesses. Following the public consultation held between 10 December 2025 and 9 January 2026, and building on the framework set out in Article 29(4) and Article 29(18), the European Commission has responded to industry concerns by introducing targeted exemptions for plastic pallets, wrappings, and straps.
This exemption offers relief for logistics and supply chain operators managing high-volume pallet operations. However, the 2030 deadline for the 40% reusable packaging target remains firm. Compliance managers should audit their full packaging portfolio now and identify where reuse investments will be needed.
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