PPWR reuse requirements bring pallets, containers and other transport packaging more directly into corporate compliance and data management programs.
Pallets and other transport packaging are moving higher on the compliance agenda in Europe as the EU’s new Packaging and Packaging Waste Regulation (PPWR) comes into force.
Regulation (EU) 2025/40 entered into force on February 11, 2025, with most provisions applying from August 12, 2026. The regulation is intended to reduce packaging waste, increase recyclability and reuse, and create more consistent packaging rules across the European Union.
While much of the attention surrounding PPWR has focused on consumer and product packaging, the regulation also specifically addresses transport packaging, including pallets, boxes, trays, plastic crates, intermediate bulk containers, drums and other load carriers. That inclusion has implications for companies that may historically have viewed pallet management primarily as an operational or purchasing issue.
“In many companies, pallets are primarily viewed from an operational perspective: Are enough available, where are they located, and what do they cost?” said Jonas Glöckler, Country General Manager DACH at CHEP, in a CHEP Germany press release. “The new regulatory requirements of the PPWR raise further questions. Companies increasingly need to know how load carriers are used, recycled, and reused. Reliable data is becoming essential.”
Pallet reuse requirements tighten in 2030
The PPWR introduces specific reuse requirements for pallets and other transport packaging beginning January 1, 2030. For most transport packaging used to move goods within the EU, companies will have to ensure that at least 40% is reusable packaging operating within a reuse system. Pallets, reusable boxes and crates, intermediate bulk containers, drums and several other transport packaging formats are specifically covered.
The requirement rises to 100% reusable packaging for certain types of shipments. That includes movements between different locations operated by the same company, even when those locations are in different EU countries, as well as movements between linked or partner companies. It also applies when one company ships goods to another company within the same EU member state.
That means, for example, that a company moving goods from its plant in France to its own warehouse in Germany would have to use reusable transport packaging for that movement. The same would generally be true when a French manufacturer ships to an unrelated French customer. Cross-border shipments between unrelated companies, by comparison, fall under the broader 40% reuse target.
The regulation places these obligations on the company using the transport packaging to put the goods on the EU market, such as a manufacturer, importer or distributor. That company does not necessarily own the pallet. A shipper using CHEP pallets, for example, can still have PPWR responsibilities even though CHEP owns the pallets. Equipment rental providers can supply the reusable assets, recovery network and data needed to support compliance, while the company shipping the goods retains responsibility for meeting the requirements that apply to its operations.
Pallet data becomes more important
CHEP is encouraging companies to examine pallet and transport packaging management as part of their wider sustainability and compliance programs, including responsibility for load carriers, traceability and the availability of data covering their use, return and reuse.
“Today, ownership means more than just control over an asset,” Glöckler said. “Companies should therefore examine early on how their pallet processes are organized and whether they can reliably meet future requirements for reuse, transparency, and data availability.”
Complex supply chains can make that task more difficult. Pallets may move between manufacturers, logistics providers, distribution centers, retailers and other trading partners, while the company responsible for PPWR compliance may have limited direct visibility into individual load carriers. That creates a growing role for pallet tracking, transaction records and reuse-system documentation.
Pooling positioned for PPWR environment
CHEP notes that pallet pooling can help companies meet some of the new PPWR requirements. Under its share-and-reuse rental model, CHEP owns the pallets while customers use them to move goods through the supply chain. CHEP manages pallet supply, collection, inspection, repair and recirculation, and also maintains data on pallet movements and reuse. That service can reduce some of the administrative burden for companies compared with managing their own pallet fleets.
Using pooled pallets, however, does not remove a company’s PPWR responsibilities. The rules generally apply to the business (‘economic operator’ in EU documents) using the transport packaging to move or place goods on the EU market, whether that business owns the pallets or rents them from a pooling provider.
A rental pooling company can provide the reusable pallets, manage their recovery and repair, and supply data on how they are used and reused. The customer, however, remains responsible for ensuring that the pallets used in its shipments comply with the PPWR requirements that apply to those shipments. The new rules make pallet visibility and documentation increasingly important, whether companies own their pallets, use an exchange pool, or participate in a reusable transport packaging rental system.
CHEP has published a white paper outlining the implications of PPWR for pallets, packaging and supply chains, along with recommendations for companies preparing for the new requirements. See CHEP: What the EU’s new sustainability regulations mean for your supply chain.
Rick LeBlanc, EMBA, is the founder and editor of Reusable Packaging News (subscribe to the free newsletter) and editor of Western Pallet Magazine. A supply chain journalist with more than 30 years of experience, he specializes in pallets, reusable packaging, material handling and related operations. Rick is co-author of Pallets: A North American Perspective and Pallets & Progress: A Collected History of Pallets and Palletized Handling 1922–1945. He is also an advisory board member of the Virginia Tech Center for Packaging and Unit Load Design. Read Rick’s full bio.
