Pallet loads: first exemptions under the PPWR

The European Commission has introduced a first technical amendment to the PPWR, the Regulation (EU) 2025/40 on packaging and packaging waste (QR CODE), marking a significant step in the implementation of the new European regulatory framework for packaging. Through a Delegated Act adopted on 25 February (QR CODE) - the first under the new regime - the European Commission has exempted pallet wrapping and straps for stabilisation and protection of products put on pallets during transport from the 100% reuse obligation originally established by the Regulation for certain intra-company and domestic operations.
The amendment concerns a limited yet particularly significant area for the logistics and manufacturing sectors. Under the initial wording of the Regulation, transport and sales packaging - including pallets, foldable plastic boxes, crates, drums and intermediate bulk containers - was included within a system of progressive targets that, from 1 January 2030, requires economic operators to ensure that at least 40% of packaging is managed through reuse systems. Certain items, such as pallet wrapping and straps, were subject to full reuse obligations in specific scenarios. It was precisely this provision that drew the attention of industrial stakeholders. Following the observations received, the Commission conducted a feasibility assessment, which found that the exclusive adoption of reusable solutions for these components could have led to disproportionate compliance costs relative to the expected environmental benefits, particularly in internal logistics operations or those confined to national territory.
Evidence regarding current technological and operational conditions indicates that transitioning to fully reusable wrapping and straps would require significant upfront investment to redesign packaging lines.
Furthermore, such a transition would entail the adoption of automated solutions for the management of reusable packaging that, at present, are not yet sufficiently developed. As a result, this shift could cause disruption to supply chains and generate additional costs for economic operators, especially those relying on transport packaging.

The exemption introduced does not alter the overall framework of the PPWR, nor the 40% target for transport and sales packaging, but gives operators greater flexibility to pursue the overall objective without constraints deemed excessive in relation to individual components. On the one hand, the decision confirms Europe’s trajectory towards circular economy models focused on waste prevention and reuse; on the other, it reflects the willingness to align regulatory instruments with the market’s actual technical and economic conditions.
In this context, the delegated act exempting wrapping and straps from the 100% reuse requirement sets a significant precedent. It signals the Commission’s readiness to adjust the scope of measures in the presence of documented operational challenges, and confirms that ongoing dialogue with industrial supply chains will continue to shape the definition of implementing rules, across technical criteria, calculation methodologies and verification procedures.