Reusability requirement vs. transport safety – what Article 29 of the PPWR means for the beverage industry.
The EU regulation requires that a large share of transport packaging be reusable. Article 29 stipulates a reuse quota of 40% from 2030 and 70% from 2040, pushing industry and logistics toward new systems. Especially for certain types of packaging, such as stretch film, this requirement has drawn criticism: studies show that reusable systems can generate higher costs and, with increased material consumption, even significantly more emissions.
Reuse, safety standards, alternatives
In October 2025, the EU Commission announced that pallet stretch films and strapping bands would be exempted, via a delegated act, from the 100% reuse requirements (for intralogistics) in Article 29(2) and (3). This exemption has been politically confirmed but has not yet been published in the Official Journal.
Also excluded from the reuse obligation are transport packaging for hazardous goods, custom packaging for large-scale machinery and equipment, flexible transport packaging that comes into direct contact with food or feed, as well as cardboard boxes.
What sounds reasonable, however, contains conflicting objectives: Reusability can impair the safety standard of the load unit for films and straps and, paradoxically, lead to a worse environmental footprint.
Reuse requirements and their scope
Article 29 of the PPWR distinguishes between two central areas of application in order to correctly reflect different logistics and organizational structures.
Cross-border transport (open supply chains):
- 40% reuse from 2030
- 70% reuse from 2040 (anzustreben)
- these apply to rigid packaging (pallets, boxes) and flexible transport packaging (stretch film, straps)
Closed-loop systems (own sites/affiliated companies):
- here a 100% reuse requirement applied
- for, e.g., in-plant shuttle transport or contract filling
- since October, an exemption from this requirement for strapping bands and films is in prospect.
These requirements are intended to strengthen the resource cycle and reduce waste.
At the same time, however, a technical problem becomes apparent: Flexible packaging such as stretch films is structurally designed for single use; they lose holding and restoring force after each cycle. Meaningful reuse is practically impossible.
Conflict of objectives between reuse and transport safety
Several industry associations point out why a generalized reuse requirement for pallet films can lead to safety and efficiency problems:
Reuse causes higher ecological burdens:
- up to 1,700% higher CO₂ emissions compared to high-quality single-use films (LCA by EuPF)
- more material usage with reusable films
- additional resource consumption due to cleaning, return transport, storage
The economic impacts are significant:
- around €5 billion in additional costs per year (RDC analysis)
- Reusable materials cause higher handling effort and infrastructure requirements
- Re-use requires return and cleaning systems that are complex and expensive
further systemic disadvantages:
- “disproportionate” operational, financial, and spatial burdens
- Reuse prevents packaging minimization because reusable solutions are significantly more material-intensive
- flexible films are necessary to safely stabilize varying loads
- Reuse requires standardization that today’s supply chains can hardly provide (EDANA)
The safety aspect intensifies the conflict of objectives:
- each new reusable film must be requalified
- strong variance in layer patterns and containers makes stable reuse unrealistic
- the risk of tilting, layer shifting, and instability increases
In summary:
Reusable solutions are generally ecologically worse, logistically complex, and risky in terms of safety. Modern single-use films with ≥ 35% PCR content often perform better and simultaneously offer higher holding forces.
Effects on the beverage industry and recommended actions
The beverage industry is particularly affected because its load units are large-volume, heavy, and subject to dynamic loads. This results in concrete risks associated with a switch to reuse.
Reuse can jeopardize load unit stability:
- higher probability of tilting
- shifted layers due to lower performance
- damaged containers and loss of reputation with retailers
Reuse leads to considerable organizational requirements:
- investments in return, cleaning, and storage systems
- longer process paths and more handling
- space requirements for reuse systems
To implement the PPWR requirements strategically and sensibly, beverage manufacturers should, in our view, consider the following measures:
- Evaluate packaging solutions with a high PCR content
- Test the stability and performance of new solutions in the test center and prepare a declaration of conformity
- Engage in a structured dialogue with associations and policymakers
- Optimize transport packaging in a systemically meaningful way to save energy, material, and costs
Conclusion:
- Article 29 of the PPWR mandates 40% reuse from 2030 and 70% from 2040, as well as 100% reuse in closed-loop systems.
- Reusable pallet films cause up to 1,700% more CO₂ emissions according to studies and increase annual costs by almost 5 billion euros.
- Industry associations warn of safety risks, logistical burdens, and poor compatibility of the reuse requirement.
- Single-use stretch films with high PCR content can be environmentally advantageous while simultaneously ensuring stable load units.
With various PPWR-compatible films with high PCR content and available with a declaration of conformity, DUO PLAST already offers constructive solutions.
(1) Corplex – Understanding the PPWR: Reuse-Quoten (40 % ab 2030, 70 % ab 2040, 100 % im Closed-Loop) und Definition der Transportverpackung
→ https://corplex.com/de/ppwr/
(2) Corplex – PPWR Exemptions: Ausnahmen für Gefahrgut, großmaßstäbliche Maschinen, Lebensmittelkontakt und Kartonagen
→ https://corplex.com/de/ppwr/
(3) European Plastics Converters (EuPC) – Exemption for pallet wrapping; Hinweis auf ≈1 700 % höhere Emissionen und ≈ 5 Mrd. € Zusatzkosten
→ https://www.plasticsconverters.eu/post/understanding-the-impacts-of-switching-to-reusable-pallet-packaging
→ https://www.plasticsconverters.eu/post/eupf-welcomes-commission-exemption-for-pallet-wrapping-and-straps-urges-science-based-consistency-u
(4) EDANA – Position on Reuse Targets Exemptions: Wiederverwendung verursacht unverhältnismäßige operative, finanzielle und räumliche Belastungen; flexible Folien bleiben unverzichtbar
→ https://www.edana.org/about-us/news/edanas-position-on-reuse-targets-exemptions
