Reusable Transport Packaging in the PPWR – the key to a greener EU

Did you know that between 2012 and 2021, packaging waste per person in the EU increased by 34 kg, totaling 189 kg of waste per capita? In 2021 only, the EU generated 84 million tons of packaging waste, with cardboard materials accounting for 40.3% of the overall total[1].

Source: European Parliament, How to reduce packaging waste in the EU (infographics), 15 November 2023. How to reduce packaging waste in the EU (infographics) | News | European Parliament (

1. The EU’s ambition to reduce packaging and packaging waste

Considering these alarming numbers, the European Commission put forth a proposal to revise the 94/62/EC Packaging and Packaging Waste Directive in November 2022, which addresses environmental issues associated with packaging and packaging waste. The revision aims to improve the efficiency of the internal market while establishing a strong and sustainable value chain.

This involves focusing on packaging design, promoting reuse, and creating high-quality products, leading to innovative and eco-friendly job opportunities in a low-carbon packaging industry. Specific goals to achieve include:

  • Decreasing the generation of packaging waste
  • Facilitating a cost-efficient transition to a circular economy for packaging
  • Encouraging the incorporation of recycled content in packaging.

While the European Commission shows ambitious objectives for the European Union to achieve climate neutrality by 2050 and full circular economy, its proposal for a Packaging and Packaging Waste Regulation (PPWR) offers room for improvement in terms of transport packaging.

In its article 26, the proposal for a PPWR:

  • Offers an ambitious reuse target for transport packaging (30% by 2030 and 90% by 2040).
  • Includes a cardboard exemption for these reuse targets.

2. Reusable Transport Packaging in the PPWR

As stated by the European Commission, the European Union must be ambitious in its waste reduction, in order to achieve its environmental objectives. Let’s dive into the reusable transport packaging section, to understand how Reusable Plastic Crates and Reusable Wooden Pallets can be helpful in achieving climate-neutrality but also how to improve the legislation’s efficiency.

Using Reusable Transport Packaging means:

  • Reducing packaging waste
  • Consuming less resources and emitting less CO2
  • Safeguarding hygiene
  • Preventing food wastage

For more information and data, have a look at our previous blog post on the benefits of Reusable Transport Packaging.

Reusable Transport Packaging is the only long-term sustainable transport packaging solution for the European Union. Targets for Reusable Transport Packaging are established in article 26 of the PPWR.

However, ambitious targets from the European Commission could be undermined by a cardboard exemption that has been included from transport packaging reuse targets. The Council of the EU also kept the exemption in its General Approach. Similarly, the European Parliament in its final position excluded certain materials once their recycling rate surpasses 85% from reusable transport packaging targets.

3. The cardboard exemption from reusable transport packaging targets

Let’s explore the cardboard exemption to comprehend how this measure will undermine the EU’s climate-neutrality goals

Prevention from a meaningful implementation of reuse targets

To achieve the reuse targets, it is important to include cardboard boxes in the efforts to scale up reusable packaging. The exemption currently in place encourages businesses to use single-use cardboard boxes instead.

The exemption proposed for cardboard boxes in article 26 of the PPWR will prevent the meaningful implementation of these reuse targets. 

According to a German NGO NABU, only in Germany cardboard makes almost 70% of the market for transport packaging.  As long as the cardboard exemption applies, the reuse targets will apply only to the rest 30% of transport packaging, of which a big part is already reusable. The same pattern applies to other Member States, except that in many Members States, to this day, reuse remains a lot less advanced than in Germany.  

Incentive to opt for single-use packaging, resulting in increased waste generation.

The current carboard exemption creates a loophole that incentivizes businesses to opt for single-use alternatives, undermining the objectives of the European Commission to reduce greenhouse gas emissions, energy use and waste.

Reusable Transport Packaging consumes 39% less energy, produces 95% less waste and emits 29% less CO2 than single-use alternatives[2].

Discourages investments in reuse systems

Furthermore, to encourage investments in reusable packaging and reuse systems, it is necessary to implement the reuse targets in 2030 in a fair and unbiased manner. Implementing such targets would foster the extensive growth of reusable transport packaging within the EU, consequently diminishing waste generation as more businesses transition to non-disposable packaging. If all types of packaging are not treated equally, the reuse sector will not be able to achieve a significant scale-up by 2040. A level playing field for all packaging types is essential for success.

4. RPE’s recommendations to make the reuse targets more efficient

Now that issues have been identified; how can the EU implement efficient reuse targets?

1. Uphold equal treatment by eliminating all material-based exemption from reuse targets

Removing all material-based exemptions from the reuse targets will ensure an equal treatment and establish a fair level-playing field. Such an initiative will encourage investments in reusable packaging and reuse systems.

2. Provide incentives for reuse systems

Introduce financial incentives or support mechanisms for businesses investing in reusable transport packaging and reuse systems. This can include tax breaks, grants, or subsidies to make the transition to reusable packaging more economically viable.

3. Collaborate with NGOs and Industry experts

Seek input and collaboration with NGOs and industry experts to leverage their knowledge and expertise in crafting effective and realistic reuse targets. Collaboration can lead to well-informed and practical solutions that align with environmental objectives.

By addressing these recommendations, the European Union can enhance the effectiveness of the proposed reuse targets in the PPWR, contributing to the overall goal of achieving climate neutrality and a circular economy by 2050.


In conclusion, the proposed PPWR by the European Commission is seen as a positive move toward achieving the EU’s environmental goals. However, concerns arise regarding an exemption for cardboard in the targets for reusable transport packaging, which could undermine the effectiveness of the overall objectives.

The exemption may incentivize businesses to choose single-use alternatives, contrary to the goal of reducing emissions and waste. To address these issues, RPE’s recommendations include eliminating material-based exemptions, providing incentives for reusable packaging, and fostering collaboration with NGOs and industry experts. By implementing these measures, the EU can strengthen its commitment to a greener future, contributing to climate neutrality and to a circular economy.

[1] European Parliament, How to reduce packaging waste in the EU (infographics), 15 November 2023. How to reduce packaging waste in the EU (infographics) | News | European Parliament (

[2] Packaging Technology and Science Journal: Life cycle inventory of reusable plastic containers and display-ready corrugated containers used for fresh produce applications