The Commission exempts stretch film and strapping from full reuse, reshaping pallet packaging reuse obligations for hundreds of thousands of logistics operators.
Pallet packaging reuse rules revised under EU packaging regulation
The European Commission has adopted a delegated act exempting stretch film and strapping used to stabilise goods on pallets from the 100% reuse obligation foreseen for certain transport flows.
The measure mainly concerns intra-company operations, exchanges between linked or partner undertakings, and deliveries between economic operators within the same Member State.
The exemption falls under Regulation (EU) 2025/40 on packaging and packaging waste, which entered into force on 11 February 2025. The regulation introduces, from 1 January 2030, binding reuse targets for specific packaging formats. Today’s decision marks the first concrete use of the delegated powers established by the new framework.
What Article 29 originally required
Article 29 sets two levels of obligations. First, a general target: at least 40% of transport packaging used annually must consist of reusable packaging placed within a reuse system. Second, for specific logistics flows, a stricter requirement applied.
For transport between sites of the same undertaking, between related companies or partners within the Union, and for deliveries between economic operators within the same Member State, Article 29(2) and (3) imposed a 100% reuse obligation for the relevant formats.
The formats covered include pallets, foldable plastic crates, boxes, trays, intermediate bulk containers, buckets, drums, canisters, and also wrapping films and strapping for load stabilisation. The exemption now applies specifically to these latter components.
Why 100% reuse was deemed disproportionate
According to the Commission’s delegated decision, requiring exclusive use of reusable film and strapping for all operations listed in Article 29(2) and (3) could entail disproportionate adaptation costs for economic operators.
Evidence gathered indicates that shifting to full reuse would require significant investment in redesigning packaging lines. New automated reuse machinery, dedicated IT systems and staff training would be necessary. At present, such solutions are not considered sufficiently mature for widespread deployment.
The Commission also highlighted the risk of supply chain disruption. For this reason, operators using film and strapping to stabilise and protect goods on pallets during transport are now exempt from the 100% reuse obligation.
How many businesses are affected
Data cited by the Commission refer to around 600,000 logistics providers operating in the EU, according to Eurostat statistics. For these companies, compliance with the stricter requirement had been estimated at approximately 610 million euros in total costs.
These costs included adapting packaging lines, potentially maintaining dual systems, purchasing automated pallet-wrapping machinery, upgrading IT systems and implementing training programmes.
Given the widespread use of stretch film and strapping in manufacturing, the number of affected businesses could have grown further. The exemption therefore reduces the immediate impact on companies active in pallet packaging reuse, while leaving the overall 40% target unchanged.
What changes for pallet packaging reuse
The exemption applies solely to the 100% reuse obligation under Article 29(2) and (3). The overall annual target of 40% reusable packaging remains in force.
In practice, stretch film and pallet strapping will no longer be subject to mandatory total reuse in the specified internal and national flows. Operators may continue using non-reusable solutions for these components, provided they comply with the aggregate target.
For the pallet packaging reuse sector, this introduces greater flexibility in managing logistics flows. Companies can adjust reuse and recycling strategies according to technical and economic feasibility, without immediate full-system replacement.
Next regulatory steps
The decision will enter into force on the twentieth day following publication in the Official Journal of the European Union. It represents the first practical application of delegated powers under the regulation.
The Commission opened the draft to public consultation between 10 December 2025 and 9 January 2026, in line with EU decision-making procedures. The measure may set a precedent for future sector-specific exemptions.
For logistics operators and companies active in pallet packaging reuse, monitoring the implementation of Regulation (EU) 2025/40 will be essential, particularly in view of the 2030 deadlines.
