Labelling & formats
PPWR transport packaging
Last regulatory verification: 12 August 2026 · 3 official sources
Transport packaging is in scope of PPWR: reuse expectations, empty-space limits, and the pallet wrapping and strapping position for logistics packaging.
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Transport packaging — pallets, crates, boxes, wrap, strapping and dunnage — is packaging under Regulation (EU) 2025/40 and carries the same conformity obligations as consumer packaging. It is also where the reuse obligations bite earliest, because closed logistics loops are the setting reuse actually works in.
What applies to logistics packaging
From 12 August 2026: technical documentation, a Declaration of Conformity, economic operator identification, the substances of concern limits, and the minimisation duty. From 1 January 2030: the 50% empty space cap on grouped and transport packaging, plus reuse targets for defined transport packaging categories. Recyclability and, for plastic packaging, recycled content follow the same 2030 timeline as everything else.
Who is responsible for what
Packaging manufacturer
Conformity of the transport packaging itself: technical documentation, Declaration of Conformity, minimisation, substances of concern, and later recyclability and recycled content.
Operator specifying the packaging
Where pallets, crates, wrap or shippers are produced to your specification or under your brand, you are typically the operator placing them on the market and the conformity duties follow you.
Logistics and 3PL operator
Operational compliance: pack-out practice that respects the empty space cap, correct use of reusable assets, and the data needed to evidence rotation.
Producer for EPR purposes
National registration, reporting and fees for the packaging placed on each national market — a separate obligation from conformity.
Pallet wrap is the quiet exposure
What to put in place now
An inventory of every transport packaging item you use
Pallets, crates, trays, corner boards, wrap, strapping, dunnage, void fill and shippers, with supplier and specification.
Usually held by: Operations / procurement
A decision on who is the manufacturer for each item
Standard bought-in items versus items made to your specification. The distinction determines who owns the Annex VII file.
Usually held by: Compliance owner
Empty space baseline per shipping configuration
Measure now, so the 2030 cap is a known gap rather than a discovery. Record inputs, not just the percentage.
Usually held by: Operations
Reuse asset data where you already run returnable packaging
Rotation counts, losses and cleaning process — the evidence base for reuse claims and target reporting.
Usually held by: Logistics
For the reuse criteria and the system conditions behind them, see reusable packaging. For the design-side duties that apply to the packaging itself, see packaging minimisation.
Official sources for this page
Every statement above is written against these sources. Where a Commission document and the Regulation differ, the Regulation controls.
- Regulation (EU) 2025/40 — EUR-LexBinding law
- PPWR Implementation HubCommission guidance
- Commission PPWR FAQCommission guidance
- Sources last verified
- 12 August 2026
- Content last updated
- 12 August 2026
- First published
- 12 August 2026
Written and maintained by the PPWRDeclaration.com editorial team. General information about Regulation (EU) 2025/40 — not legal advice.
Why this matters
What happens if the documentation isn't there
The packaging can be restricted
Packaging without valid technical documentation is treated as non-compliant. Market surveillance authorities can require corrective action, restrict sale, or withdraw it from the market.
Penalties apply per Member State
Each Member State sets its own penalties for non-compliance, and they apply where the packaging is placed on the market — not where your business sits.
Buyers block you first
Retailers, distributors and importers increasingly ask for the Declaration and supporting evidence before onboarding. No file usually means no listing.
Late evidence costs more
Supplier declarations and lab testing have long lead times. Discovering a gap close to a deadline forces rushed testing or packaging redesign.