Pallet wrap and straps: the first PPWR delegated act, and what it leaves open
Since 26 May 2026, stretch wrap and straps no longer have to be 100% reusable between sites or within a country. Whether they still count towards the 40% target is not settled.
The Commission's first delegated act under PPWR's reuse article concerns the film and straps that hold loads on pallets. Commission Delegated Decision (EU) 2026/429 was adopted on 25 February 2026, published in the Official Journal on 6 May and in force from 26 May 2026 (Delegated Decision (EU) 2026/429).
What it changes
Without the decision, Article 29(2) and (3) would have required pallet wrap and straps to be reusable within a reuse system from 2030:
between an operator's own sites;
for deliveries to other companies in the same Member State.
The decision exempts wrap and straps from those 100% duties. The Commission's explanatory memorandum points to around 600,000 logistics businesses affected and adaptation costs of roughly €610 million (Commission, C(2026) 511, 25 February 2026).
EPAL welcomed the exemption when it was proposed (EPAL, 9 January 2026).
What it leaves open
The draft said the general 40% target would not apply to these uses either. That sentence is not in the version published in the Official Journal. EPR organisations such as EXPRA read the final text as leaving wrap and straps inside the 40% aggregate (EXPRA, 23 March 2026). The Commission's implementing act on how to calculate the targets, due by 30 June 2027, is the likely place for a clear answer. Until then this is an open question.
Plastic wrap still has its own recycled-content target under Article 7. The exemption only concerns reuse.
What it means for the pallets themselves
Nothing changes for the pallet. A wooden pallet travelling between two Swedish companies must still be reusable within a reuse system from 2030. Keeping wrap and pallets apart in your records matters: they are separate formats in the calculation, even though the FAQ says they may form one "transport unit" (PPWR FAQ).
In Resupply, deliveries are recorded by pallet type and count per counterparty, so pallets are tracked on their own, separate from the wrap.
General information, not legal advice.
Questions about your own flows? Ask Resupply for a short PPWR proposal: resupply.se (in Swedish).