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Regulation of logistics packaging in the EU: A guide for industrial companies

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Reading time: 5 minutes | Category: Packaging Regulations | Last updated: June 2026

A wide range of standards, laws, and regulations apply to industrial and logistics packaging. Many of these originate from the European Union; some are global in scope. European examples include PPWR (Packaging & Packaging Waste Regulation) and EPR (Extended Producer Responsibility). An example of a global standard is ESG (Environmental, Social, and Governance). On this page, we focus primarily on European regulations that are enforceable at the local or European level by public authorities.

 

Page Contents

 

Why PPWR applies to you even if you don’t manufacture consumer goods

Your customers are starting to ask whether you comply with PPWR requirements. Procurement managers are receiving sustainability questionnaires from parent companies about supply chain practices. Certification audits now include questions about packaging materials that you were not even considering two years ago.

However, the main problem is not what you don’t know. The problem is that companies perceive this regulation as a matter for manufacturers and sellers of consumer goods – supermarkets, food producers, and e-commerce. Industrial logistics, after all, deals with transport crates, KLT boxes, and pallets, not plastic bags in shops.

Yet PPWR in its currently applicable form affects industrial packaging quite significantly – in three areas with a direct financial impact:

  • Limits on empty space in packaging (void space; applicable from 1 January 2030 at the earliest): empty space in a transport package may not exceed 50% of its volume. Filler material is counted as empty space. It does not matter whether you use plastic, paper, or another material – it all counts toward empty space.
  • Reuse targets: companies transporting packaging within one country or between their own plants must use 100% reusable transport packaging from 2030.
  • EPR (Extended Producer Responsibility) fees with eco-modulation: for every piece of packaging that ends up as waste after use, a fee is payable. The fee will vary depending on how easily recyclable the packaging is.

The good news: companies that already work with returnable industrial packaging in a closed logistics loop are naturally better prepared for PPWR than their competitors who still rely on single-use cardboard. PPWR essentially codifies what good industrial logistics has been doing for several years.

This page will give you a comprehensive overview of what PPWR requires from (not only) industrial companies, when each part of the regulation is set to apply, and how to respond to individual obligations without unnecessary alarm.

 

What PPWR actually is and what it is not

PPWR (Packaging and Packaging Waste Regulation, EU Regulation 2025/40) is a Union regulation that, from 12 August 2026, replaces the existing Directive 94/62/EC on packaging and packaging waste.

The key difference from a directive: a regulation is directly applicable in all EU member states without the need for transposition into national law. There is no Czech-German-Austrian PPWR. The regulation applies equally in Prague, Munich, and Vienna.

 

What PPWR is not

A number of myths circulate in the industry around PPWR that are worth dispelling:

PPWR does not require the immediate abolition of all single-use packaging. The regulation works with gradual targets and transitional periods extending to 2040. Companies have time to prepare and transition progressively.

PPWR does not require certification of each individual piece of packaging. There is no “PPWR packaging certification” that you would need to demonstrate to customers. There are declarations of conformity and recyclability documentation – but these relate primarily to packaging manufacturers, not to those who purchase packaging.

PPWR does not retroactively cover packaging already in circulation. New obligations apply to packaging placed on the market after the date of entry into force of the regulation.

PPWR is not only about plastic packaging. It covers all materials – cardboard, wood, metal, and plastic. A company that switches from plastic to cardboard packaging on the grounds that “it is more eco-friendly” may not comply with PPWR requirements any better.

For precise wording and definitions of key terms, see our glossary: PPWR – Packaging and Packaging Waste Regulation

 

Classification of packaging and what it means for industrial companies

PPWR classifies packaging by its function in the value chain. Understanding this classification will save you unnecessary worry about obligations that do not apply to you, while helping you focus on what truly lies ahead.

Primary packaging protects and presents the product to the consumer – it is what the customer buys in a shop and holds in their hand. If you do not manufacture consumer packaged goods, you are watching the majority of the requirements relating to labeling and recyclability of primary packaging from a distance.

Secondary packaging groups together primary packages – the transport cartons in which goods travel from production to the shelf. For purely industrial B2B companies, this is again only a peripheral matter.

Tertiary packaging serves to protect goods during transport and handling in the supply chain – and this is where the core issue lies for industrial companies. KLT boxes, KTP boxes, plastic pallets, gitterboxes, transport crates, dividers, and inserts – these are tertiary packaging, and PPWR sets specific obligations for them with real deadlines.

Summary for industrial companies: PPWR primarily affects you through tertiary transport packaging. Track three things – void space, reuse targets, and EPR. Watch the rest of the regulation from a distance.

→ More detail on individual packaging types can be found in our glossary.

 

PPWR timeline: an overview of key dates and obligations 2025–2040

Overview of key dates for industrial companies – listed chronologically from the nearest:

Date

Obligation

11 February 2025

PPWR entered into force

12 August 2026

General applicability of the regulation – from this date, PPWR replaces Directive 94/62/EC

12 August 2026

Prohibition on food packaging containing PFAS above specified limit values

12 February 2028

Obligation to minimize empty space in sales packaging

Aug 2028 (or +24 months from implementing acts)

Packages must bear a harmonized label indicating material composition

Feb 2029 (or +30 months from implementing acts)

Reusable packaging must bear a QR code on reusability

1 January 2030

Void space max. 50% of transport packaging volume

1 January 2030

Minimum 35% recycled content in plastic transport packaging

1 January 2030

40% of transport packaging must pass through a reuse system (exceptions in the FAQ section)

1 January 2030

100% reusable packaging for B2B transport within the Czech Republic or the enterprise group

1 January 2038

Packaging must be recyclable only in grade A or B

1 January 2040

Minimum 65% recycled content in plastic transport packaging

1 January 2040

Best-efforts target to achieve 70% of transport packaging in a reuse system (exceptions in the FAQ section)

Note on conditional deadlines: A number of deadlines depend on when the relevant implementing acts of the Commission enter into force. The rule “whichever is later” applies – if the Commission fails to adopt implementing acts in time, the actual obligation is postponed. Monitor the current status accordingly.

→ Complete overview of all deadlines including Commission obligations, transitional provisions, etc.: PPWR timeline: an overview of key dates and obligations 2025–2040

 

What the PPWR Regulation Means for Companies That Use Industrial Packaging

The answer to this question depends largely on the type of packaging these companies use. For single-use packaging that ends up as waste after a single use, PPWR and EPR may bring new costs in the form of system fees.

PPWR does not require the immediate abolition of all single-use packaging. However, it sets targets for the share of reusable packaging in various sectors. Industrial companies will not be able to avoid these targets.

The good news is that companies already using returnable packaging in a closed logistics loop are naturally prepared to meet these requirements. A system of KLT crates, plastic pallets, or KTP boxes circulating between a plant and suppliers, or a leased pool of transport crates – these are exactly the models PPWR is designed to support.

If you are still using single-use cardboard packaging for transports that repeat regularly on the same route, switching to returnable packaging is the most direct path to meeting PPWR requirements. We examine in detail how returnable packaging helps with PPWR compliance in the article “How returnable industrial packaging helps meet PPWR reuse requirements”.

→ A more detailed analysis of individual requirements for industrial companies can be found in the standalone article PPWR: What the EU regulation means for companies that use industrial packaging.

 

How Returnable Industrial Packaging Helps Meet PPWR Reuse Requirements

Every KLT box, KTP container, or plastic pallet circulating in a closed logistics loop naturally meets PPWR targets – the 40% target for transport packaging by 2030 and the 100% obligation for B2B transport within one country or a group of enterprises. However, two things are key: a system for returning packaging so that it counts towards reuse targets, and data on the number of cycles so that compliance can be demonstrated during an audit.

→ How to plan the transition in practice, what the PPWR specifically requires of returnable packaging, and when to start: How returnable industrial packaging helps meet PPWR reuse requirements.

 

Frequently Asked Questions Your Customers May Pose to You

This question is aimed more at packaging manufacturers than at their users. If you are a packaging buyer, ask your supplier for: a declaration of recyclability of the material, the proportion of recycled content in the packaging, and the EPR system to which it contributes. If your supplier does not have this data, it is a signal to reconsider the supplier relationship.

You should know this figure. Go through the transport packaging used in regular logistics flows. What percentage of it is returned after delivery? If you don’t know, start working on tracking. You can make this easier by leasing logistics packaging. With leased packaging, it is clear that repeated use is occurring. Any disposal (and the resulting EPR obligations) is handled by the lessor.

Cross-border transports within a group of companies are subject to the 100% returnable packaging requirement (Article 29(2)). The 100% share of returnable packaging also applies to packaging used for deliveries of goods to other companies within the same state. The 40% target applies only to cross-border transports between organizationally unrelated enterprises (Article 29(1)). However, there are further exceptions to the rule for packaging:

  1. used for the transport of dangerous goods in accordance with Directive 2008/68/EC;
  2. used for the transport of large machinery, equipment, and commodities that are custom-designed to meet the individual requirements of the economic operator placing the order;
  3. in flexible format used for transport that is in direct contact with food and animal feed;
  4. in the form of cardboard boxes.

Cardboard boxes are exempt from the 100% target for transport within an enterprise (Art. 29(2)) and within one country (Art. 29(3)), as well as from the 40% target (Art. 29(1)). The exemption thus covers all three provisions.

Sanctions for breach of the regulation are set by each member state independently – the Czech Republic must notify the Commission by 12 February 2027. The specific level of sanctions for the Czech Republic has not yet been determined. Beyond direct sanctions, there is a reputational risk vis-à-vis customers who require PPWR compliance as a condition of cooperation. We are already encountering this requirement now (June 2026), for example in the automotive sector.

The Digital Product Passport (DPP) is a digital identity for a product that will contain information about materials, recyclability, and the product’s history. PPWR itself does not set a specific timetable for DPP for packaging. It refers to Regulation (EU) 2024/1781 on ecodesign, where DPP obligations are to be introduced gradually through product-specific delegated acts. When and for which packaging categories the DPP obligation will apply depends on whether and when the Commission adopts the relevant delegated act for a given product type. The natural technological basis for DPP compliance is packaging tracking systems with QR codes or RFID tags – the same infrastructure that PPWR requires for labeling reusable packaging.

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