The PPWR timeline, and what to do now

PPWR comes in stages. Some obligations apply already; others wait for acts the Commission has not yet adopted. The dates below are from the regulation itself (Regulation (EU) 2025/40) unless another source is linked. Where a date depends on an act that is late, we say so.

The dates

• 22 January 2025. Published in the Official Journal.

• 11 February 2025. Entry into force. The definition of reusable packaging (Art. 11(1)) applies to packaging placed on the market from this date.

• 12 August 2026. General application, and the old directive is repealed. From now:

- conformity assessment, technical documentation and the EU declaration of conformity (Arts. 15, 38, 39); - identification and the manufacturer's details on the packaging (Art. 15); - the heavy-metal limit (Art. 5(4)); - reuse system rules (Arts. 26–27, Annex VI); - ten-year traceability for reusable packaging (Art. 22).

• 12 February 2027. Due: the minimum number of rotations for reusable packaging (Art. 11(2)) and national penalty rules (Art. 68).

• 30 June 2027. Due: the method for calculating reuse targets (Art. 30(3)).

• 1 January 2028. Due: design-for-recycling criteria, including for wood (Art. 6(4)).

• 12 February 2028. Due: the method for the empty-space ratio (Art. 24(2)).

• 12 February 2029 at the earliest. The reusable-packaging label and QR code (Art. 12(2)). This doesn't apply to open loops without a system operator, such as the Euro pallet exchange (PPWR FAQ).

• 1 January 2030. Most of the big rules start:

- reuse targets: 40% overall, 100% within a company and within a country (Art. 29); - minimisation (Art. 10) and empty space of at most 50% (Art. 24); - recyclability grades (Art. 6), or 24 months after the criteria if those come later; - 2030 is the first reporting year for reuse, with the report due within six months (Art. 31).

• 1 June 2030. First harmonised EPR reporting, according to the Commission's FAQ.

• 1 January 2034. The Commission reviews the 2030 reuse targets and may propose changes to the 2040 ones (Art. 29(19)).

• 1 January 2040. Operators should "endeavour" to reach 70% reuse for transport packaging.

What is late

As of October 2026, several acts that were due have not appeared:

• the format of national producer registers (due February 2026; a draft was open for comment in August–September 2026);

• the labels (due August 2026; now planned for the second quarter of 2027, Commission "Have your say").

The work on minimum rotations is under way through a Commission study, with a stakeholder workshop on 16 November 2026 (FEFPEB newsletter, October 2026).

Separately, the Commission proposed in December 2025 to suspend the duty to appoint an authorised representative for EPR in other Member States (Art. 45(3)). Parliament voted its position on 20 October 2026, and the Council agreed its own the following day. The final text is still to be negotiated (Packaging Europe, 23 October 2026).

What to do now

If you make or repair pallets:

• Work out whether you are the "manufacturer" of what you sell. Unbranded pallets usually make you the manufacturer and producer; pallets to a licensed standard such as EPAL have their own arrangements.

• Make sure there is a declaration of conformity and a technical file for each product type.

• Check your marking: the identifier and your name and address, or an accompanying document where marking isn't possible.

• Keep records of who you supply reusable pallets to. The requirement is ten years.

If you ship goods on pallets:

• Map your flows for 2030:

- between your own sites (100%); - to companies in the same country (100%); - to other EU countries and from imports (the 40% aggregate).

• Note which flows already run on reusable pallets inside a reuse system, and which run on one-way pallets.

• Start counting now, per year, in units. The calculation method arrives in 2027, but 2030 is the first reporting year, and a baseline from 2027–2029 shows where the gaps are.

If you run a pool or a reuse system:

• Check your system against Annex VI: governance, equal access, return and reject data, and EPR for packaging that becomes waste.

• Decide whether you are a closed loop with a system operator, which brings labels, QR codes and rotation reporting from 2029, or an open loop.

Doing the counting once, not every year

The pattern across these steps is the same: records per flow, per counterparty and per year, kept for a decade. Companies that already balance pallet exchanges with their suppliers have most of the raw material, but it often sits in paper waybills, ERP comments and a spreadsheet per supplier.

Resupply records each pallet movement once, on a phone at the dock:

• the delivery, the counterparty and site, and the pallet types and counts, read from a photo of the waybill;

• deviations, which become claims;

• sorting and reconditioning, as handlings.

Balances per counterparty follow from those records. Resupply is building PPWR on top of them: which deliveries are inside a reuse system, reuse shares per counterparty and site, and the yearly export for the report. The 2027–2029 baseline can then build up as part of daily work.

General information, not legal advice. Dates that depend on late acts may move.

Not sure which dates apply to you? Resupply can put together a short proposal showing which PPWR requirements apply to your company: resupply.se (in Swedish).