How Should PPWR Reuse Be Assessed for Packaging Systems and Their Components?
Reuse under the PPWR is assessed at Packaging System level, not at supplier component level.
From 1 January 2030, economic operators must ensure that at least 40% of the relevant transport packaging and sales packaging used for transporting products, including e-commerce deliveries, is reusable and used within a system for re-use. The target is calculated over each calendar year across the applicable packaging formats in total, subject to specific exemptions such as cardboard boxes. A higher indicative target of 70% applies from 2040, while the detailed harmonised calculation and verification methodology must still be established by the European Commission.
How to classify reusables
A Packaging System is not classified as reusable based on the percentage of reusable Packaging Components. It is reusable when its main functional packaging item, such as a Container, crate or pallet, completes multiple rotations within a system for re-use.
For pallet configurations, the reusable pallet, single-use pallet wrapping and single-use straps remain separate packaging formats for Article 29. Pallet wrapping and straps are exempt from the 100% reuse requirements for certain transport flows, but are not automatically exempt from the general 40% reuse target.
Cardboard boxes are exempt from the Article 29 reuse targets. This exemption does not automatically apply to all paper or cardboard formats, such as cardboard trays, cardboard corner protectors, cardboard interlayers and cardboard sleeves.
See below for the Reuse Checklist, to be completed for each Packaging System.

How Is the 40% Reuse Target Calculated?
The 40% reuse target is assessed at economic-operator level over a calendar year for the relevant in-scope transport packaging formats in total. The calculation is expected to reflect the actual volume of packaging used, meaning that quantities, shipments, use events and rotations may influence the result. A Packaging System used for one shipment should therefore not necessarily have the same contribution as one used thousands of times.
It is not currently defined as:
- 40% of all Packaging Systems;
- 40% of all Packaging Components;
- 40% of all SKUs;
- 40% of packaging weight;
- 40% of pallet configurations.
The final harmonised calculation and verification methodology has not yet been adopted. It is therefore not yet definitively established whether packaging will be counted by units used, initial placements on the market, shipments, rotations, weight or another normalised measure, nor how different packaging formats such as pallets, crates, wrapping, straps and trays will be combined or weighted.
When Will the EU Reuse Calculation Methodology Be Available?
The European Commission must adopt the harmonised calculation and verification methodology by 30 June 2027. The 40% reuse target applies from 1 January 2030, or 18 months after the methodology enters into force, whichever is later. Until the implementing act is adopted, the exact treatment of quantities, shipments, rotations and different packaging formats remains subject to further clarification.