---
title: "PPWR reuse and refill targets: Article 29 and take-away duties"
canonical_url: "https://www.sorena.io/artifacts/eu/packaging-waste-regulation/reuse-and-refill-targets"
source_url: "https://www.sorena.io/artifacts/eu/packaging-waste-regulation/reuse-and-refill-targets"
author: "Sorena AI"
description: "source-linked guide to PPWR reuse targets for transport, grouped, beverage, and take-away packaging, including Article 29, 32, 33, reporting, and exemptions."
published_at: "2026-05-09"
updated_at: "2026-05-09"
keywords:
  - "PPWR reuse targets"
  - "PPWR refill obligations"
  - "Article 29 PPWR"
  - "Article 33 PPWR"
  - "reusable packaging"
  - "transport packaging"
  - "grouped packaging"
  - "beverage packaging"
  - "take-away packaging"
  - "Regulation (EU) 2025/40"
  - "PPWR"
  - "reuse targets"
  - "refill obligations"
  - "Article 29"
  - "Article 33"
---
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---

# PPWR reuse and refill targets: Article 29 and take-away duties

source-linked guide to PPWR reuse targets for transport, grouped, beverage, and take-away packaging, including Article 29, 32, 33, reporting, and exemptions.

*PPWR* *Reuse and refill* *Article 29*

## PPWR reuse and refill targets Article 29 and take-away obligations

Map the PPWR reuse targets that apply to transport, grouped, beverage, and take-away packaging.

Use the official Regulation text to separate binding 2030 targets, 2040 endeavour levels, refill duties, take-back duties, and exemptions.

PPWR reuse and refill work starts by identifying the packaging format, economic operator role, Member State territory, and sales channel. Article 29 sets reuse targets for specified transport, grouped, and beverage packaging; Articles 32 and 33 add refill and reusable-offer duties for take-away food and beverages.

## Which PPWR reuse targets apply from 2030?

Article 29 creates separate target buckets. Do not average transport packaging, grouped packaging, beverage sales packaging, or take-away offers together unless the Regulation or a later methodology allows it.

For transport packaging and sales packaging used for transport, the 2030 baseline is at least 40 percent reusable packaging within a re-use system. For certain internal-site, linked-enterprise, partner-enterprise, or same-Member-State B2B deliveries, Article 29 instead requires the listed transport packaging to be reusable within a re-use system from 1 January 2030.

- Transport packaging and sales packaging used for transport: at least 40 percent reusable in 2030, with a 70 percent 2040 endeavour level.
- Internal-site, linked-enterprise, partner-enterprise, and same-Member-State B2B transport flows: listed formats must be reusable within a re-use system from 2030.
- Grouped packaging in boxes other than cardboard, outside sales packaging, for stock-keeping or distribution units: at least 10 percent reusable in 2030, with a 25 percent 2040 endeavour level.
- Alcoholic and non-alcoholic beverages made available to consumers in sales packaging: at least 10 percent in reusable packaging in 2030, with a 40 percent 2040 endeavour level.
- Article 29 targets are calculated for a calendar year, so evidence should be tied to yearly packaging units, sales units, or beverage volume.

Sources for this answer:

- [Regulation (EU) 2025/40 on packaging and packaging waste](https://data.europa.eu/eli/reg/2025/40/oj?ref=sorena.io) - Article 29 is the binding source for PPWR reuse targets, target years, format buckets, exclusions, and calendar-year calculation.
- [Packaging & Packaging Waste Regulation](https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste/packaging-packaging-waste-regulation_en?ref=sorena.io) - European Commission overview page confirming the policy direction on reuse, refill, collection, and mid-2026 application timing.

## Which Article 29 exclusions and exemptions need a decision record?

Reuse-target applicability should be recorded format by format. Article 29 excludes several transport and sales-packaging uses from the paragraph 1 to 3 transport obligations, and it creates separate exemptions for beverage final distributors and small economic operators.

Teams should not treat an exemption as automatic unless the evidence file shows the exact threshold, product category, location condition, or Member State decision that supports it.

- Transport exclusions include dangerous-goods transport, custom-designed packaging for large-scale machinery, equipment, or commodities, certain flexible formats in direct contact with food or feed, and cardboard boxes.
- Beverage target exclusions include highly perishable beverages, milk and listed milk products, specified grapevine products, aromatised wine products, certain other fermented beverages, and alcohol-based spirituous beverages under CN heading 2208.
- A final distributor with a sales area of not more than 100 square meters is exempt from Article 29 beverage targets for that calendar year.
- Member States may exempt relevant final distributors on islands with fewer than 2,000 inhabitants or in municipalities below the specified population-density condition, subject to the Article 29 text.
- Micro-enterprises that make not more than 1,000 kilograms of packaging available in a Member State during the calendar year are exempt from Article 29 targets for that year.

Sources for this answer:

- [Regulation (EU) 2025/40 on packaging and packaging waste](https://data.europa.eu/eli/reg/2025/40/oj?ref=sorena.io) - Article 29 paragraphs 4, 7, 10, 11, and 13 support the exclusion and exemption checks listed here.

## How do refill and take-away obligations fit with reuse targets?

PPWR refill duties are not just a marketing option. Article 32 requires HORECA final distributors that sell hot or cold beverages or ready-prepared food in take-away packaging to provide a system for consumers to bring their own container by 12 February 2027.

Article 33 then adds a reusable-packaging offer for the same take-away context by 12 February 2028, with no higher cost and no less favourable conditions than the same product in single-use packaging. From 2030, those final distributors must endeavour to offer 10 percent of products for sale in a reusable packaging format.

- For take-away refill, keep the point-of-sale sign or board, consumer-container rules, and price-condition evidence together.
- For reusable take-away packaging, keep the system-for-reuse evidence, point-of-sale consumer information, price comparison, and micro-enterprise exemption check together.
- For refill stations, record the hygiene standards, accepted container types, end-user responsibility rules, and whether any container supplied at the station is charged or part of a deposit and return system.
- For large final distributors, track whether sales area exceeds 400 square meters and whether the operator has assessed the Article 28 refill-station endeavour.

Sources for this answer:

- [Regulation (EU) 2025/40 on packaging and packaging waste](https://data.europa.eu/eli/reg/2025/40/oj?ref=sorena.io) - Articles 28, 32, and 33 support the refill-station, take-away refill, and take-away reusable-offer obligations.
- [Packaging & Packaging Waste Regulation](https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste/packaging-packaging-waste-regulation_en?ref=sorena.io) - European Commission overview page summarising PPWR encouragement of reuse, refill, and collection options.

## What evidence supports Article 29 reporting?

Article 30 separates calculation evidence by target. For transport and grouped packaging targets, the operator needs equivalent units of reusable packaging within a re-use system and equivalent units of other relevant packaging used in the calendar year.

For beverage targets and Article 33, final distributors need sales units or total beverage volume in reusable packaging within a re-use system and the corresponding sales units or volume in other packaging. Article 31 requires annual reporting to the competent authority within six months after the reporting year.

- Maintain a format-level inventory for every Article 29 packaging bucket rather than one combined reuse percentage.
- Preserve the system-for-reuse evidence, including operator, participant, collection, reconditioning, refill or reload, and reporting rules where relevant.
- Keep Article 30 calculation worksheets by calendar year and by target.
- Prepare for the first Article 31 reporting year: calendar year 2030.
- Track Commission implementing acts on the calculation methodology because the demonstration obligation applies from 1 January 2030 or 18 months after the methodology act enters into force, whichever is later.

Sources for this answer:

- [Regulation (EU) 2025/40 on packaging and packaging waste](https://data.europa.eu/eli/reg/2025/40/oj?ref=sorena.io) - Articles 30 and 31 support the target-calculation records, reporting deadline, first reporting year, and competent-authority reporting channel.
- [Register of delegated and implementing acts](https://webgate.ec.europa.eu/regdel/?ref=sorena.io) - European Commission register to monitor delegated and implementing acts that may specify PPWR calculation, pooling, or exemption details.

*Recommended next step*

*Placement: after evidence section*

## Turn PPWR reuse targets into a reporting workflow

Map each packaging format, operator role, exemption decision, calculation method, and evidence owner before 2030 reporting starts.

- [Open Research Copilot](/solutions/research-copilot.md): Answer PPWR reuse and refill questions with cited source material.
- [Discuss PPWR implementation](/contact.md): Review Article 29 scope, refill duties, source evidence, and next implementation steps with Sorena.

## Where do teams usually make mistakes on PPWR reuse and refill?

The common failure is to reduce reuse and refill to a sustainability claim before confirming the legal bucket. A beverage final distributor, a transport-packaging user, a grouped-packaging user, and a HORECA take-away operator can face different duties, dates, evidence, and exemptions.

Another frequent error is using 2040 endeavour levels as if they were the same kind of obligation as the 2030 targets. The page, evidence file, and internal controls should preserve the Regulation's wording and distinguish mandatory targets from endeavour language.

- Do not cite a general refill statement as proof that a specific Article 29 target is met.
- Do not apply the beverage target to excluded beverage categories without checking Article 29 paragraph 7 and Commission guidance when available.
- Do not omit take-back evidence where beverage reusable packaging is made available under Article 29 paragraph 6.
- Do not count packaging as reusable unless it is within a system for re-use and the Article 11 reusable-packaging conditions are considered.
- Do not publish a reuse percentage unless the Article 30 calculation basis is clear.

Sources for this answer:

- [Regulation (EU) 2025/40 on packaging and packaging waste](https://data.europa.eu/eli/reg/2025/40/oj?ref=sorena.io) - Article 11 supports reusable-packaging conditions; Articles 29 to 33 support the separate target, reporting, refill, and reusable-offer duties.
- [Packaging and packaging waste statistics](https://ec.europa.eu/eurostat/statistics-explained/index.php/Packaging_waste_statistics?ref=sorena.io) - Eurostat packaging-waste statistics help teams explain why reuse and refill data should be kept as measurable packaging records, not generic claims.

## Primary sources

- [Regulation (EU) 2025/40 on packaging and packaging waste](https://data.europa.eu/eli/reg/2025/40/oj?ref=sorena.io) - Official Journal text for PPWR Article 29 reuse targets, Article 30 calculation, Article 31 reporting, Article 32 take-away refill, and Article 33 take-away reusable offers.
  - Quote: "Regulation (EU) 2025/40"
- [Packaging & Packaging Waste Regulation](https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste/packaging-packaging-waste-regulation_en?ref=sorena.io) - European Commission overview page for the PPWR policy context, including reuse, refill, collection, and application timing.
  - Quote: "Packaging & Packaging Waste Regulation"
- [Register of delegated and implementing acts](https://webgate.ec.europa.eu/regdel/?ref=sorena.io) - European Commission register for tracking delegated and implementing acts relevant to PPWR reuse-target calculation and related details.
  - Quote: "delegated and implementing acts"
- [Packaging and packaging waste statistics](https://ec.europa.eu/eurostat/statistics-explained/index.php/Packaging_waste_statistics?ref=sorena.io) - Eurostat statistics page for packaging-waste context and packaging data discipline; it is not the binding source for Article 29 obligations.
  - Quote: "Packaging waste statistics"

## Related Topic Guides

- [EU PPWR Conformity Documentation Guide](/artifacts/eu/packaging-waste-regulation/conformity-documentation.md): Build PPWR technical documentation and EU declarations of conformity for packaging, with evidence fields, owner checks, retention rules, and official EU sources.
- [EU PPWR penalties and fines: Article 68 enforcement guide](/artifacts/eu/packaging-waste-regulation/penalties-and-fines.md): Source-grounded guide to PPWR penalties and fines: Article 68 Member State rules, administrative fines for Articles 24 to 29, market-surveillance action, formal non-compliance, and enforcement evidence.
- [PPWR applicability test: packaging scope, roles, and evidence](/artifacts/eu/packaging-waste-regulation/applicability-test.md): Determine whether the EU Packaging and Packaging Waste Regulation applies to a packaging item, market activity, operator role, and evidence workflow.
- [PPWR Article 12 labelling, QR codes, and digital carriers](/artifacts/eu/packaging-waste-regulation/labelling-qr-and-digital-carriers.md): source-linked guide to PPWR Article 12 packaging labels, reusable packaging QR codes, digital carriers, online-sale information, and evidence records.
- [PPWR Article 33 refill targets and take-away container reuse obligations](/artifacts/eu/packaging-waste-regulation/reuse-refill-targets.md): source-linked guide to PPWR reuse and refill targets for transport, grouped, beverage, and take-away packaging under Articles 29 to 33.
- [PPWR Article 5 PFAS and Restricted Substances Guide](/artifacts/eu/packaging-waste-regulation/pfas-and-restricted-substances.md): Grounded guide to PPWR Article 5 substance controls: substances of concern, the 100 mg/kg heavy-metal cap, PFAS limits for food-contact packaging, and technical-documentation evidence.
- [PPWR Article 5 PFAS Evidence Workflow for Food-Contact Packaging](/artifacts/eu/packaging-waste-regulation/pfas-evidence-workflow.md): Build a PPWR Article 5 evidence workflow for food-contact packaging PFAS checks, limit-value evidence, supplier proof, and Annex VII technical documentation.
- [PPWR compliance checklist for packaging teams](/artifacts/eu/packaging-waste-regulation/checklist.md): source-linked PPWR checklist for packaging scope, recyclability, recycled content, PFAS, minimisation, labelling, conformity files, and EPR registration under Regulation (EU) 2025/40.
- [PPWR compliance guide: packaging conformity, EPR and evidence](/artifacts/eu/packaging-waste-regulation/compliance.md): Build a PPWR compliance workflow for packaging placed on the EU market, covering Articles 5-12 controls, conformity assessment, technical files, declarations, labelling, EPR and evidence.
- [PPWR compostable packaging rules: what must be compostable?](/artifacts/eu/packaging-waste-regulation/faq/compostable-packaging.md): A PPWR FAQ on compostable packaging: mandatory compostable formats, Member State options, recycling default rules, labels, and evidence to retain.
- [PPWR deadlines and compliance calendar](/artifacts/eu/packaging-waste-regulation/deadlines-and-compliance-calendar.md): Calendar-style PPWR deadline guide for application, PFAS, labelling, recyclability, recycled content, reuse, refill, deposit return, reporting, and transition dates.
- [PPWR delegated and implementing act tracker](/artifacts/eu/packaging-waste-regulation/delegated-act-tracking.md): Track PPWR delegated and implementing acts for recyclability, recycled content, reuse, labelling, EPR, reporting, and evidence owners.
- [PPWR e-commerce packaging rules: empty space, labels, and reuse](/artifacts/eu/packaging-waste-regulation/faq/e-commerce-packaging.md): source-linked FAQ for online sellers and fulfilment teams applying PPWR rules to e-commerce packaging, including empty-space, labelling, reuse, and evidence records.
- [PPWR Economic Operator Roles: manufacturers, importers, distributors and producers](/artifacts/eu/packaging-waste-regulation/economic-operator-roles.md): Map PPWR roles for packaging teams: manufacturer conformity files, importer and distributor checks, supplier data, fulfilment handling, traceability, and EPR producer registration.
- [PPWR EPR and Producer Responsibility Guide](/artifacts/eu/packaging-waste-regulation/epr-and-producer-responsibility.md): Map PPWR EPR duties for producers, authorised representatives, producer responsibility organisations, online platforms, registrations, reporting and evidence under Regulation (EU) 2025/40.
- [PPWR FAQ: Scope, Recyclability, Reuse, Labelling, and EPR](/artifacts/eu/packaging-waste-regulation/faq.md): FAQ index for Regulation (EU) 2025/40 on packaging and packaging waste, covering PPWR scope, recyclability, recycled content, minimisation, reuse, labelling, EPR, and evidence.
- [PPWR grouped and transport packaging empty-space FAQ](/artifacts/eu/packaging-waste-regulation/faq/grouped-and-transport-packaging.md): Answer whether grouped, transport, and e-commerce packaging need PPWR empty-space controls, what the 50% ratio covers, and what evidence to keep.
- [PPWR labelling and consumer information requirements](/artifacts/eu/packaging-waste-regulation/labeling-and-consumer-info.md): Article 12 and Article 55 PPWR guidance for packaging labels, QR codes, online sales information, waste receptacle labels, and consumer information records.
- [PPWR labelling checklist for Articles 12 and 13](/artifacts/eu/packaging-waste-regulation/ppwr-labeling-checklist.md): Checklist for PPWR Article 12 packaging labels and Article 13 waste-receptacle labels, including material composition, reuse, DRS, digital carriers, online sales, and transition stock.
- [PPWR labelling dates: when do packaging labels apply?](/artifacts/eu/packaging-waste-regulation/faq/labelling-dates.md): A PPWR FAQ on Article 12 and Article 13 labelling dates for packaging, reusable packaging, recycled-content labels, QR codes, waste receptacles, and implementation acts.
- [PPWR labelling rollout workflow for Article 12 and 13](/artifacts/eu/packaging-waste-regulation/labelling-rollout-workflow.md): source-linked workflow for rolling out PPWR Article 12 packaging labels, QR codes, reusable packaging labels, recycled-content labels, and Article 13 waste-receptacle labels.
- [PPWR micro-enterprise and small business FAQ](/artifacts/eu/packaging-waste-regulation/faq/micro-and-small-business-edge-cases.md): source-linked FAQ on PPWR micro-enterprise and small business edge cases, including manufacturer responsibility, reuse exemptions, packaging restrictions, refill, and evidence records.
- [PPWR packaging classification guide: sales, grouped, transport and e-commerce packaging](/artifacts/eu/packaging-waste-regulation/packaging-classification.md): Classify PPWR packaging by function, material category, format, reuse status and operator role before assessing recyclability, restrictions, EPR and documentation.
- [PPWR Packaging Minimisation Guide: Article 10 Evidence](/artifacts/eu/packaging-waste-regulation/minimization.md): source-linked PPWR packaging minimisation guide covering Article 10, Annex IV evidence, perceived-volume bans, empty-space rules, and technical documentation.
- [PPWR packaging scope workflow: classify packaging, roles, and evidence](/artifacts/eu/packaging-waste-regulation/packaging-scope-workflow.md): A PPWR packaging scope workflow for classifying packaging, assigning economic-operator roles, routing EPR questions, and keeping technical evidence.
- [PPWR PFAS Rules for Food-Contact Packaging](/artifacts/eu/packaging-waste-regulation/pfas-and-food-contact-packaging.md): source-linked guide to PPWR Article 5 PFAS limits for food-contact packaging, including the 12 August 2026 date, thresholds, and evidence records.
- [PPWR PFAS Thresholds for Food-Contact Packaging](/artifacts/eu/packaging-waste-regulation/faq/pfas-thresholds.md): Direct FAQ on the PPWR Article 5 PFAS limits for food-contact packaging, including the 25 ppb, 250 ppb, and 50 ppm thresholds.
- [PPWR Recyclability and Design-for-Recycling Requirements](/artifacts/eu/packaging-waste-regulation/recyclability-and-design-requirements.md): Article 6 PPWR guide to packaging recyclability grades, Annex II packaging categories, design-for-recycling parameters, recycled-at-scale assessment, and evidence files.
- [PPWR Recyclability Assessment Template](/artifacts/eu/packaging-waste-regulation/ppwr-recyclability-assessment-template.md): Use this PPWR recyclability assessment template to record packaging category, DfR parameters, performance grade evidence, recycled-at-scale evidence, and approval owners.
- [PPWR Recyclability Assessment Workflow | Article 6 and Annex II](/artifacts/eu/packaging-waste-regulation/recyclability-assessment-workflow.md): Assess PPWR recyclability by packaging unit: map the Annex II category, screen design-for-recycling parameters, grade the result, and retain Annex VII evidence.
- [PPWR recyclability grades A, B and C explained](/artifacts/eu/packaging-waste-regulation/recyclability-grades.md): Understand PPWR recyclability grades under Article 6 and Annex II, including design-for-recycling thresholds, 2030, 2035 and 2038 timing, and evidence records.
- [PPWR recycled content calculations: Article 7 FAQ](/artifacts/eu/packaging-waste-regulation/faq/recycled-content-calculations.md): A PPWR FAQ on recycled content calculations for plastic packaging: Article 7 scope, manufacturing-plant averages, Commission methodology timing, exceptions, and evidence.
- [PPWR Recycled Content Targets for Plastic Packaging](/artifacts/eu/packaging-waste-regulation/recycled-content-targets.md): Article 7 PPWR targets for recycled content in plastic packaging, including 2030 and 2040 percentages, calculation basis, exclusions, and evidence records.
- [PPWR requirements overview for EU packaging teams](/artifacts/eu/packaging-waste-regulation/requirements.md): A grounded overview of Regulation (EU) 2025/40 requirements for packaging scope, recyclability, recycled content, minimisation, labelling, reuse, EPR, and conformity evidence.
- [PPWR reusable packaging and re-use systems FAQ](/artifacts/eu/packaging-waste-regulation/faq/reusable-systems.md): Answer when packaging can be treated as reusable under PPWR, what re-use systems must include, and what evidence teams should keep.
- [PPWR reuse target applicability workflow: Article 29 and 33](/artifacts/eu/packaging-waste-regulation/reuse-target-applicability-workflow.md): source-linked workflow to decide whether PPWR Article 29 reuse targets, Article 32 refill duties, and Article 33 take-away reusable offers apply.
- [PPWR scope and packaging definitions: Article 2 and Article 3 guide](/artifacts/eu/packaging-waste-regulation/scope-and-packaging-definitions.md): Use PPWR Article 2 and Article 3 to decide whether an item is packaging, classify sales, grouped, transport, e-commerce and service packaging, and record source-linked evidence.
- [PPWR service packaging FAQ: point-of-sale and takeaway rules](/artifacts/eu/packaging-waste-regulation/faq/service-packaging.md): Service packaging under the EU PPWR means items designed to be filled at the point of sale. See scope, takeaway, HORECA refill and reuse, and evidence checks.
- [PPWR vs ESPR: Packaging Rules vs Product Ecodesign](/artifacts/eu/packaging-waste-regulation/ppwr-vs-espr.md): Compare PPWR and ESPR without mixing duties: PPWR controls packaging and packaging waste, while ESPR is a separate sustainable-product ecodesign framework that PPWR complements.
- [PPWR vs REACH: Packaging Waste vs Chemicals Rules](/artifacts/eu/packaging-waste-regulation/ppwr-vs-reach.md): Compare PPWR packaging duties with the narrow REACH boundary confirmed in PPWR sources: substances in packaging, PFAS, recyclability, labelling, EPR, evidence, and dates.
- [PPWR vs RoHS: Packaging vs EEE Compliance](/artifacts/eu/packaging-waste-regulation/ppwr-vs-rohs.md): Compare PPWR packaging duties with a separate RoHS workstream, including scope, owners, evidence, dates, overlap limits, and source-linked PPWR decision points.
- [PPWR vs Single-Use Plastics Directive: Packaging Scope and Overlap](/artifacts/eu/packaging-waste-regulation/ppwr-vs-sup-directive.md): Compare PPWR and the Single-Use Plastics Directive without merging duties: all-packaging PPWR rules, listed single-use plastic product rules, overlap, evidence, and 2030 changes.
- [PPWR vs Waste Framework Directive: Packaging Duties and WFD Links](/artifacts/eu/packaging-waste-regulation/ppwr-vs-waste-framework-directive.md): Compare PPWR with the Waste Framework Directive where the PPWR text expressly relies on WFD concepts: waste hierarchy, definitions, EPR, collection, traceability, and waste plans.
- [Timeline and Deadlines for PPWR: practical implementation guide](/artifacts/eu/packaging-waste-regulation/timeline-and-deadlines.md): Practical PPWR guidance for Timeline and Deadlines, with source-linked decisions, owners, evidence records, and implementation steps.


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