The reuse targets explained: 40%, 100% and the reuse system

Article 29 is the part of PPWR that the pallet industry talks about most, and the part most often summarised wrongly. Here is what the text says (Regulation (EU) 2025/40, Art. 29–31).

What is covered

The targets cover transport packaging, and sales packaging used for transport, in the form of:

• pallets;

• foldable plastic boxes, boxes, trays and plastic crates;

• intermediate bulk containers, pails, drums and canisters;

• pallet wrap and straps used to stabilise loads on pallets.

They apply "of any size or material", so wood is in. The Commission's FAQ treats the list as exhaustive. Interlayers, for example, are not on it (PPWR FAQ, 2nd edition, August 2026).

The obligation sits with the company that uses the packaging to transport products. The Commission's guidance reads that as the company placing the product on the EU market in that packaging: the manufacturer, importer or distributor (Commission Notice C/2026/3084).

Three cases from 1 January 2030

1. The general case: 40%. Of all covered packaging an operator uses within the EU, at least 40% must be reusable packaging within a reuse system (Art. 29(1)). From 2040 the aim is 70%, but the text says operators "shall endeavour", which is softer than the 2030 duty.

2. Between your own sites: 100%. Packaging moving between sites of the same operator, or to linked or partner enterprises, must be reusable within a reuse system (Art. 29(2)).

3. To another company in the same country: 100%. Packaging used to deliver products to another economic operator within the same Member State must also be reusable within a reuse system (Art. 29(3)).

For a Swedish food producer delivering to a Swedish wholesaler on pallets, case 3 applies: from 2030 those pallets must be reusable within a reuse system. Exports to another Member State fall under the 40% aggregate.

The exemptions

• Art. 29(4). None of the three cases applies to packaging for dangerous goods, to custom-designed packaging for large machinery and equipment, to flexible packaging in direct contact with food or feed, or to cardboard boxes. The guidance says the custom design must be documented in the technical file.

• Micro-enterprises that make no more than 1,000 kg of packaging available in a Member State in a year are exempt (Art. 29(13)). Both conditions must hold.

• A national five-year exemption (Art. 29(14)) is possible, but only for Member States that beat the recycling targets by 5 percentage points, have cut packaging waste per person by 3% since 2018, and for operators with a waste prevention and recycling plan. It can be renewed.

• Further exemptions by delegated act (Art. 29(18)), for sectoral economic constraints, hygiene or environmental reasons.

Pallet wrap and straps

The first delegated act under Article 29 concerns wrap and straps. Commission Delegated Decision (EU) 2026/429 (in force 26 May 2026) exempts them from the 100% rules in cases 2 and 3 (Delegated Decision (EU) 2026/429). Reusable stretch wrap between two Swedish companies is not required.

Whether the 40% aggregate still counts wrap and straps on those flows is disputed. The Commission's February draft said the quotas would not apply to those uses; the version published in the Official Journal does not have that sentence. EPAL and several EPR organisations read it as the 40% still applying (EPAL, 9 January 2026; EXPRA, 23 March 2026). Expect the calculation rules to settle it. This is an open question.

What counts as a reuse system

A reusable pallet alone isn't enough. It has to circulate "within a reuse system" that meets Annex VI. Annex VI distinguishes:

• Closed loops, where a system operator or cooperating group circulates the packaging without a change of ownership. The rental pool model fits here. That is our reading of the definitions: the Commission hasn't classified individual pools by name.

• Open loops, where the packaging changes hands among an open number of participants.

Open loops without a system operator are spared some Annex VI duties, the reusable label and QR code, and rotation reporting. The Commission's FAQ names the Euro pallet exchange as this kind of system. Our piece [Pooling or one-way?](/pooling-or-one-way-pallets) compares the models.

How it will be counted

• Operators count equivalent units of reusable and other packaging used per calendar year (Art. 30(1)).

• The Commission must adopt the calculation method by 30 June 2027 (Art. 30(3)). The duty to show you meet the target starts on 1 January 2030, or 18 months after that act if later (Art. 30(4)).

• Operators report to their national authority within six months of each year's end. The first year is 2030, and the reports are made public (Art. 31).

• The Commission still has to set the minimum number of rotations that makes packaging "reusable" (Art. 11(2), due February 2027). FEFPEB has said it will present the industry's view at the Commission consultants' workshop on 16 November 2026 (FEFPEB newsletter, October 2026).

What the counting means in practice

Whatever the final method, the number will come from your own records:

• how many units of each type you used in a year;

• how many of them were reusable and inside a reuse system;

• which flows were intra-company, domestic or cross-border;

• which were exempt.

If pallet movements are only visible in invoices and freight documents, rebuilding that once a year is slow and easy to dispute.

At Resupply every delivery is recorded with its counterparty, site, pallet types and counts, at the dock and on a phone. The waybill photo fills in the details. Exchanges are tied to the packaging agreement with each counterparty, so it is clear which flows run in which system. Resupply is building the PPWR layer on top: a reuse status for each delivery, reuse shares per counterparty and site, and the yearly figures for the authority's report.

General information, not legal advice. The calculation rules are not yet adopted.

See which targets apply to your flows: ask Resupply for a short proposal at resupply.se (in Swedish).