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Articles 11 and 29(1) of the new EU Packaging Regulation (PPWR) mark the start of a new phase in the European circular economy. From 12 August 2026, packaging must be designed in such a way that it can be reused multiple times or integrated into functioning return and reuse systems. The Regulation also makes it clear that transport packaging in the B2B sector must in future be transferred to reusable systems. This applies both to internal transport within companies and to business relationships between companies.
For the economic operators concerned, this means that focusing on robust reusable concepts is no longer a strategic option, but a binding regulatory requirement.
The Regulation has two main objectives:
| Aspect | Article 11 – Reusable packaging | Article 29(1) – Reuse targets |
|---|---|---|
| Objective | Introduction of functioning reusable and return systems | Increase in the share of reusable packaging across all packaging sectors |
| Application | From 12 August 2026 | Phased in up to 2040 (depending on packaging type) |
| Obligations for companies | Packaging must be capable of multiple uses, returnable and repairable | Reuse quotas must be achieved progressively and demonstrated |
| Verification & monitoring | Participation in a reuse system, documentation and labelling (digital from 2028) | National monitoring of target achievement by Member States |
| Delegated acts | Determination of minimum numbers of rotations by February 2027 | Definition of specific quotas and transitional periods |
| Practical implications | Establishing or connecting to reusable systems, reviewing existing packaging for reusability | Strategic planning to comply with future reuse quotas and adapt packaging portfolios |
The European Commission has explicitly ruled out a formal postponement of the PPWR. At the same time, the Commission announced that it would examine pragmatic corrective mechanisms within the existing legal framework. The aim is to make implementation in 2026 feasible and to resolve issues of responsibility among the parties concerned.
The obligations will therefore come into force as planned from August 2026, whilst Member States prepare their national implementing regulations in parallel. In Germany, a concrete proposal is already in place in the form of the draft bill to amend packaging legislation (VerpackDG), which sets out responsibilities, procedures and penalties. As a result, companies are increasingly focusing not only on EU-wide obligations but also on national enforcement.
When it comes to reusability, systemic recycling and robust traceability in accordance with the PPWR, many existing packaging solutions face structural challenges.
That is why, with the fixed start date, legally compliant, durable and tried-and-tested reusable systems are becoming established in strategic decision-making.
Stainless steel IBCs and KEGs already meet key requirements of the PPWR:
This provides businesses with a high degree of planning and investment certainty when implementing the forthcoming regulations.
The regulatory framework is in place and forms the basis for the upcoming requirements for packaging systems.
Reusable, returnable and repairable packaging solutions become a mandatory field of action.
Delegated act on minimum rotation numbers for reusable packaging; HORECA must allow the filling of customers’ own containers.
EU guidelines for design for recycling and harmonised labelling; New requirement: reusable option for takeaway.
Reusable packaging requires the label „reusable“, including a QR code; deposit and return systems with a 90 % collection rate.
Start of reusable packaging and recycled content quotas, first bans and a reduced volume of waste of minus 5 %.
The reuse obligation is not a short-term project, but requires early planning. This includes assessing existing packaging, setting up or integrating with reusable systems, and preparing for digital proof of compliance.
We can help you understand the PPWR requirements and develop viable solutions for your specific container systems.
