The European Commission has adopted a Delegated Decision exempting pallet wrapping and straps from the Packaging and Packaging Waste Regulation (PPWR) requirement that these formats be used in 100 percent reusable systems for certain transport applications.
The Delegated Decision, adopted February 25, 2026, applies to economic operators that use pallet wrappings and straps to stabilize and protect products during transport. Under the decision, these formats are exempt from the 100 percent reuse obligations set out in Article 29(2) and 29(3) of Regulation (EU) 2025/40.
Those articles would otherwise have required pallet wrappings and straps used for transports within the same company, between linked or partner companies, or for deliveries within the same Member State to always be reusable within a reuse system.
The exemption does not remove pallet wrappings and straps from the PPWR’s overall transport packaging framework. From January 1, 2030, economic operators must still ensure that at least 40 percent of transport and sales packaging placed on the market is reusable across a defined set of formats, which includes pallets, crates, foldable plastic boxes, intermediate bulk containers, drums, and canisters.
Commission cites disproportionate adaptation costs
In its explanatory memorandum, the Commission states that there is “strong evidence that the exclusive use of reusable pallet wrappings and straps” in all cases covered by Article 29(2) and (3) could lead to disproportionate adaptation costs for operators.
The document points to high initial investments required to redesign packaging lines, including the need for new automated machinery, IT systems, and staff training. It also notes that automated reusable wrapping solutions are not yet sufficiently developed at scale and that a forced shift could disrupt supply chains.
According to Eurostat-based estimates referenced in the Delegated Decision, approximately 600,000 logistics providers in the EU could be affected by Article 29(2) and (3), with adaptation costs estimated at roughly €610 million. The Commission adds that the number of affected businesses could be significantly higher when manufacturing users of pallet wrap and straps are iincluded.
Flexibility within overall reuse targets remains
The PPWR establishes an overall 40 percent reuse target for transport packaging under Article 29(1). The regulation allows operators to compensate formats with lower reuse rates by achieving higher reuse rates in other transport packaging formats.
The Commission notes that exempting pallet wrappings and straps from Articles 29(2) and (3) does not prevent operators from using reusable versions of these products. Reusable pallet wraps and straps are commercially available and already used in certain applications.
Industry concerns about weakening reuse signals
The exemption follows months of debate within the reusable transport packaging community.
In a February 2026 position paper, Green Spider Reusable Pallet Wraps urged policymakers to maintain the PPWR’s reuse requirements for pallet wrappings and straps, arguing that broad exemptions risk slowing innovation and infrastructure development for reusable systems.
Green Spider has pointed to evidence that well-designed reusable pallet wrap systems can achieve dozens, and in some cases hundreds, of use cycles in closed or semi-closed logistics loops. The company argues that environmental and economic performance improve significantly when trip rates exceed 50 cycles.
In a recent Reusable Packaging News op ed, this publication cautioned against what it described as “binary thinking” around reuse. The article acknowledged that implementing reuse can be difficult in long, fragmented supply chains with uncertain backhaul flows, but also noted that reuse is demonstrably viable in closed distribution loops, high-volume flows between fixed sites, centralized warehouse models, and integrated manufacturing networks.
That op ed argued that Article 29 was originally designed to encourage system-wide optimization rather than rigid compliance at the individual format level, and suggested that targeted, evidence-based flexibility may be preferable to blanket exemptions.
What this means for operators
For pallet users and stretch film suppliers, the Delegated Decision removes the risk of mandatory conversion to 100 percent reusable wrap and straps for intra-company and intra-Member State transport.
At the same time, the broader PPWR reuse framework remains intact. Operators will still need to evaluate how pallet wrap and straps fit into their overall transport packaging reuse strategies as they work toward the 40 percent reuse requirement by 2030.
The Delegated Decision enters into force 20 days after publication in the Official Journal of the European Union.
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.
