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PPWRApplicability workflowArticles 29-33

PPWR reuse target applicability Article 29 and Article 33 workflow

Classify whether a packaging flow is covered by PPWR reuse targets, take-away refill duties, or reusable-offer requirements.

Use the workflow to separate transport, grouped, beverage, and HORECA take-away cases before calculation, reporting, or customer-facing claims.

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Author
Sorena AI
Published
May 9, 2026
Updated
Oct 15, 2026
5 sections4 primary sources
Overview

Use this workflow to decide which PPWR reuse or refill rule applies. A combines the organisational, technical, or financial arrangements and incentives needed to collect packaging and use it again; a reusable design or claim alone is not enough. Article 29 sets separate 2030 reuse targets for specified transport, grouped, and beverage packaging. Article 32 requires covered hotel, restaurant, and catering (HORECA) businesses to provide a system for consumers to bring their own containers from 12 February 2027, and Article 33 requires a reusable-packaging offer from 12 February 2028. Start with the operator, packaging format, Member State, sales channel, and exemption evidence.

Section 1

Step 1: identify the operator role and packaging flow

Article 29 does not apply one reuse percentage to every packaging case. It creates separate routes for economic operators using specified transport packaging, economic operators using non-cardboard boxes as grouped packaging outside sales packaging, and final distributors making covered beverages available to consumers in sales packaging.

Record the legal role first. A marketplace, brand owner, logistics operator, HORECA final distributor, beverage final distributor, or packaging supplier can hold different evidence, even when they touch the same packaging system.

  • Transport route: check whether the operator uses transport packaging, or sales packaging used for transporting products, in the Article 29 paragraph 1 formats.
  • Internal or same-Member-State transport route: check whether Article 29 paragraph 2 or 3 makes the listed transport packaging reusable within a from 1 January 2030, then apply Decision (EU) 2026/429's exemption for pallet wrappings and straps.
  • Grouped-packaging route: check whether boxes other than cardboard are used outside sales packaging to create stock-keeping or distribution units.
  • Beverage route: check whether the final distributor makes alcoholic or non-alcoholic beverages in sales packaging available to consumers in a Member State.
  • Take-away route: check separately whether the final distributor is in the HORECA sector and sells hot or cold beverages or ready-prepared food in take-away packaging.
Section 2

Step 2: assign the Article 29 target bucket

Once the flow is in scope, classify it into the specific Article 29 bucket instead of creating a blended reuse answer. The transport, grouped, and beverage rules use different targets, calculation records, and exemption checks.

Keep 2030 obligations separate from 2040 endeavour levels. The evidence file should preserve the Regulation's wording and show which target is being tested.

  • Transport packaging under Article 29 paragraph 1: at least 40 percent of the listed packaging in total must be reusable packaging within a from 1 January 2030, with a 70 percent 2040 endeavour level.
  • Transport packaging under Article 29 paragraph 2 or 3: the listed transport packaging must be reusable within a from 1 January 2030, except that Decision (EU) 2026/429 exempts pallet wrappings and straps used to stabilise and protect products on pallets from these 100 percent requirements.
  • Grouped packaging under Article 29 paragraph 5: at least 10 percent reusable packaging within a from 1 January 2030, with a 25 percent 2040 endeavour level.
  • Beverage sales packaging under Article 29 paragraph 6: at least 10 percent of covered products made available in reusable packaging within a from 1 January 2030, with a 40 percent 2040 endeavour level.
  • Beverage reusable packaging under Article 29 paragraph 9: verify free take-back at the point of sale and deposit redemption or notification under the rules.
Section 3

Step 3: test exclusions, exemptions, and pooling before assigning work

Applicability work is incomplete until the team tests exclusions and exemptions against the exact route. Some exclusions apply only to the transport obligations; others apply to the beverage target; Article 33 has its own exemption.

Do not treat an exemption as a permanent product attribute. Several checks depend on a calendar year, a sales area, a Member State decision, or secondary legislation. Decision (EU) 2026/429 is already in force and changes the Article 29(2) and (3) result for pallet wrappings and straps without removing those formats from Article 29(1).

  • Transport exclusion check: dangerous-goods transport, custom-designed packaging for large machinery, specified flexible food or feed contact transport formats, and cardboard boxes are outside Article 29 paragraphs 1 to 3.
  • Pallet-wrapping and strap check: Decision (EU) 2026/429 exempts these formats from Article 29(2) and (3)'s 100 percent reuse requirements when they stabilise and protect products on pallets, but they remain in Article 29(1)'s overall 40 percent transport-packaging target.
  • Beverage exclusion check: Article 29 paragraph 7 excludes listed highly perishable, milk, grapevine, aromatised wine, other fermented, and spirituous beverage categories.
  • Beverage final-distributor exemption check: Article 29 exempts a final distributor from paragraph 6 for a calendar year when its sales area is not more than 100 square metres.
  • Location exemption check: verify whether the Member State has granted an Article 29(11) exemption for a sales area on an island with fewer than 2,000 inhabitants or in a municipality with fewer than 54 people per square kilometre. The low-density route does not exempt sales areas in population centres with more than 5,000 inhabitants. An exempt distributor selling the covered beverages in reusable packaging must still arrange take-back under Article 29(9).
  • check: Article 29 paragraph 13 requires both micro-enterprise status and no more than 1,000 kg of packaging made available in the Member State during that calendar year. Article 33 paragraph 4 exempts micro-enterprises from the reusable-offer duty without that packaging-quantity condition.
  • Pooling check: where a Member State allows beverage pooling, record the pool members, pool manager, market-share limit, brand condition, and competent-authority information.
Section 4

Step 4: branch HORECA take-away cases into Articles 32 and 33

A HORECA take-away case can require both a consumer-container refill route and a reusable-packaging offer route. Treat Articles 28, 32, and 33 as separate but connected branches: Article 28 sets operating rules for refill, Article 32 sets the own-container duty, and Article 33 sets the reusable-packaging offer.

The take-away branch should also connect to Annex VI. Refill stations need visible hygiene, container, and contact information; re-use systems need governance, collection, reconditioning, reporting, and cost-allocation rules, subject to the specified open-loop exceptions.

  • Article 32 refill branch: by 12 February 2027, covered HORECA final distributors must provide a system for consumers to bring their own container for hot or cold beverages or ready-prepared food in take-away packaging.
  • Article 32 price and information branch: the product in the consumer's container must cost no more and be offered on no less favourable conditions than the same product in single-use packaging, with visible point-of-sale information.
  • Article 28 container branch: communicate the accepted container types, hygiene standards, and consumer health-and-safety responsibilities; a business may refuse a container that does not follow those rules, including one it considers unhygienic or unsuitable for food or drink.
  • Article 33 reusable-offer branch: by 12 February 2028, covered HORECA final distributors must give consumers the option of reusable packaging within a system for re-use.
  • Article 33 endeavour branch: from 2030, final distributors must endeavour to offer 10 percent of products for sale in a reusable packaging format.
  • Annex VI evidence branch: keep governance rules, participant roles, return incentives, reconditioning rules, reporting rules, and refill-station information records where applicable.
Section 5

Step 5: prepare calculation, reporting, and review records

A reuse decision should end in records that can be recalculated by target and by calendar year. Article 30 requires separate calculations for the Article 29 target being demonstrated. Article 31 requires the economic operators referred to in Article 29(1) to (8) to report Article 29 target data to the competent authority for each calendar year; Article 33 alone does not create that filing duty.

The workflow should stay open until the Article 30 methodology implementing act is tracked. The obligation to demonstrate Article 29 target achievement applies from 1 January 2030 or 18 months after that implementing act enters into force, whichever is later.

  • Record the Article 29 or Article 33 route, operator role, Member State territory, packaging format, product category, and exemption result.
  • For Article 29 paragraphs 1 and 5, keep equivalent units of reusable packaging within a and equivalent units of other relevant packaging used in the calendar year.
  • For Article 29 paragraph 6, keep either total sales units or total beverage volume in reusable packaging within a and the corresponding total in other packaging. For Article 33, keep sales units or beverage volume as applicable. Article 30 requires the two targets to be calculated separately.
  • For operators covered by Article 29(1) to (8), prepare Article 31 reporting records for the first reporting year, calendar year 2030, and the six-month reporting window after the reporting year.
  • Assign an owner to monitor Commission guidance on Article 29 beverage scope, the Article 30 calculation methodology, pooling conditions, and delegated exemptions.
Recommended next step

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Primary sources

References and citations

Regulation (EU) 2025/40 on packaging and packaging waste
data.europa.eu6 citations
Referenced sections
  • Official Journal text for PPWR Article 29 reuse targets, Article 30 calculation, Article 31 reporting, Article 32 take-away refill, Article 33 reusable offers, and Annex VI reuse/refill system requirements.
  • Article 29 identifies the operator roles, packaging formats, and product routes that trigger reuse-target checks.
  • Article 29 paragraphs 1, 2, 3, 5, 6, 9, and 17 support the target buckets, dates, take-back check, and calendar-year treatment.
Show 3 more
  • Article 29 paragraphs 4, 7, 10, 11, 12, 13, and 18 support the exclusion, exemption, pooling, and delegated-act checks.
  • Articles 28, 32, and 33 support the HORECA refill operating rules, own-container duty, and reusable-offer branch; Annex VI supports system and refill-station evidence.
  • Articles 30 and 31 support the calculation, methodology, demonstration, first reporting year, and competent-authority reporting records.
"Regulation (EU) 2025/40"
More quoted passages
"Re-use targets"
"Targets laid down in or pursuant to this Article shall be calculated"
"obligations under this Article"
"Re-use offer obligation"
"Rules on the calculation"
Commission Delegated Decision (EU) 2026/429 on pallet wrappings and straps
data.europa.eu2 citations
Referenced sections
  • Binding secondary law exempting pallet wrappings and straps used to stabilise and protect products on pallets from the 100 percent reuse requirements in Article 29(2) and (3).
  • Article 1 exempts pallet wrappings and straps used to stabilise and protect products on pallets from the 100 percent reuse requirements in Article 29(2) and (3), while leaving Article 29(1)'s overall target in place.
Packaging & Packaging Waste Regulation
environment.ec.europa.eu2 citations
Referenced sections
  • European Commission overview page for PPWR reuse, refill, collection, and mid-2026 application context.
  • European Commission overview page summarising PPWR policy direction on reuse, refill, collection, and no-extra-charge options where available.
"Packaging & Packaging Waste Regulation"
More quoted passages
"reuse or refill options"
Register of delegated and implementing acts
webgate.ec.europa.eu2 citations
Referenced sections
  • European Commission register for monitoring future PPWR implementing and delegated acts relevant to Article 29 calculation, pooling, and exemptions.
  • European Commission register for tracking delegated and implementing acts that may specify PPWR calculation, pooling, or exemption details.
"delegated and implementing acts"

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