Pooling or one-way? How pallet models fit PPWR

PPWR does not tell anyone to join a pool. It says that from 2030 a share of the transport packaging you use, all of it in some flows, must be reusable packaging within a reuse system (Regulation (EU) 2025/40, Art. 29). Which system you use is up to you. The models differ in what they demand of you.

The regulation's two kinds of loop

Annex VI defines two kinds of reuse system:

• Closed loop. Packaging circulates through a system operator or a cooperating group of companies, without a change of ownership.

• Open loop. Packaging circulates among an unspecified number of participants, and ownership changes along the way.

Every reuse system must have governance, rules that give users equal access, a design that reaches the minimum number of rotations, and a system operator that reports rotations, rejects and return rates. It must also make sure producer responsibility is met when packaging becomes waste. Two kinds of open loop get relief from some of these duties:

• loops without a system operator;

• loops that existed before the regulation entered into force.

The Euro pallet exchange: an open loop without an operator

The Commission's FAQ uses the Euro pallet as its example of an open-loop system without a system operator. There is a standard and licensed producers and repairers, but no one runs the circulation (PPWR FAQ, 2nd edition, August 2026). EPAL describes its pool the same way in its declarations of conformity (EPAL EU declaration of conformity, Euro pallets, July 2026).

For users that brings real simplifications:

• no reusable-packaging label and QR code (Art. 12(3));

• no rotation reporting.

It also leaves a gap. Nobody in the exchange keeps the records for you. Each company still has to show, for its own reuse target, how many units it used and that they were reusable within the system.

Rental pools: closed loops with an operator

In the rental model the pool operator owns the pallets and users hire them. That matches the regulation's closed loop. This is our reading of Annex VI; the Commission has not classified individual pool operators by name.

The operator carries the system duties: governance, reporting of rotations and return rates, and from 2029 the reusable label and a QR code or similar carrier for tracking. The guidance says the system operator is typically the "manufacturer" of reusable packaging in a closed loop (Commission Notice C/2026/3084).

Grocery and trade pools

Several Nordic trades run their own shared systems for pallets and crates, owned by the trade itself. Where such a system has an operator and keeps ownership of the packaging, it looks like a closed loop. Where pallets change hands, it is closer to an open loop. How each one classifies itself is for its operator to set out. We cover the Nordic systems in [The Nordic picture](/ppwr-nordic-picture-sweden-norway-denmark-finland).

One-way pallets

A one-way pallet is single-use packaging. It is allowed, but it counts against you:

• From 2030 it can't be used between your own sites, or to deliver to another company in the same Member State. Those flows must be 100% reusable (Art. 29(2)–(3)).

• In cross-border flows it fills the 60% of the aggregate that may be non-reusable.

• Export pallets that leave the EU are outside the targets, which apply only within the Union.

The Commission's guidance says that for imports the targets start at the first warehouse in the EU.

Repair is part of the system

Annex VI counts repair as part of reconditioning, and Member States may count repaired wooden packaging towards their recycling targets (Art. 54(2)). For repairers and sorters, PPWR makes their role more visible, not smaller. The regulation also expects reuse systems to know their reject and return rates, and those numbers come from the sorting floor.

Whichever model: the records are yours

Across all three models one thing stays with each company: being able to show, per year and per flow, how many units it used, in which system, and with which counterparties. Pools record what happens inside the pool. They don't record your mix of exchange pallets, rental pallets, one-way pallets and crates across all your suppliers and customers.

Resupply works alongside any pool. It keeps the record for each company:

• every delivery and return, with its counterparty, site, pallet types and counts, captured on a phone at the dock;

• balances per counterparty under each packaging agreement;

• deviations as claims;

• sorting and reconditioning as handlings.

The agreement tells which system a flow runs in. Resupply is building PPWR on top of these records: a reuse status for each delivery, the mix of reuse systems, and reuse shares per counterparty and site.

General information, not legal advice. Classification of specific pools is for their operators and the authorities.

Running more than one pallet model? Ask Resupply for a short proposal on what PPWR means for your flows: resupply.se (in Swedish).