---
title: "PPWR reuse target applicability workflow: Article 29 and 33"
canonical_url: "https://www.sorena.io/artifacts/eu/packaging-waste-regulation/reuse-target-applicability-workflow"
source_url: "https://www.sorena.io/artifacts/eu/packaging-waste-regulation/reuse-target-applicability-workflow"
author: "Sorena AI"
description: "source-linked workflow to decide whether PPWR Article 29 reuse targets, Article 32 refill duties, and Article 33 take-away reusable offers apply."
published_at: "2026-05-09"
updated_at: "2026-05-27"
keywords:
  - "PPWR reuse target applicability workflow"
  - "Article 29 PPWR"
  - "Article 33 PPWR"
  - "Article 32 PPWR"
  - "reuse targets"
  - "refill obligation"
  - "reusable packaging"
  - "take-away packaging"
  - "transport packaging"
  - "grouped packaging"
  - "beverage packaging"
  - "PPWR"
  - "Regulation (EU) 2025/40"
  - "Article 29"
  - "Article 33"
  - "refill obligations"
---
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# PPWR reuse target applicability workflow: Article 29 and 33

source-linked workflow to decide whether PPWR Article 29 reuse targets, Article 32 refill duties, and Article 33 take-away reusable offers apply.

*PPWR* *Applicability workflow* *Articles 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.

This PPWR workflow helps teams decide whether Article 29 reuse targets, Article 32 refill duties, or Article 33 take-away reusable-offer duties apply to a packaging flow. Start with the operator role, packaging format, Member State territory, channel, and exemption evidence before assigning a target or publishing a reuse claim.

## 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 transport packaging, economic operators using grouped packaging outside sales packaging, and final distributors making 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 re-use system from 1 January 2030.
- 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.

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 identifies the operator roles, packaging formats, and product routes that trigger reuse-target checks.

## 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 reusable packaging within a re-use system 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 re-use system from 1 January 2030.
- Grouped packaging under Article 29 paragraph 5: at least 10 percent reusable packaging within a re-use system 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 re-use system 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 re-use system rules.

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 1, 2, 3, 5, 6, 9, and 17 support the target buckets, dates, take-back check, and calendar-year treatment.

## 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 micro-enterprise 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 future delegated acts.

- 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.
- 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 the sales area is not more than 100 square meters.
- Location exemption check: Member States may exempt certain final distributors on islands with fewer than 2,000 inhabitants or in municipalities below the specified population-density condition.
- Micro-enterprise check: Article 29 paragraph 13 and Article 33 paragraph 4 use micro-enterprise status, but the Article 29 exemption also requires the packaging-quantity condition for that calendar year.
- Pooling check: where a Member State allows beverage pooling, record the pool members, pool manager, market-share limit, brand condition, and competent-authority information.

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, 12, 13, and 18 support the exclusion, exemption, pooling, and delegated-act checks.

## 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 Article 32 and Article 33 as separate workflow branches, because they have different dates and evidence.

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.

- 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: consumer-container refill must be no higher cost and no less favourable than the same product in single-use packaging, with visible point-of-sale information.
- 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 re-use system governance rules, participant roles, return incentives, reconditioning rules, reporting rules, and refill-station information records.

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 32 and 33 support the HORECA take-away refill and reusable-offer branches; Annex VI supports system and refill-station evidence.
- [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 policy direction on reuse, refill, collection, and no-extra-charge options where available.

## 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, and Article 31 requires reporting to the competent authority for each calendar year.

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 re-use system and equivalent units of other relevant packaging used in the calendar year.
- For Article 29 paragraph 6 and Article 33, keep sales units or beverage volume in reusable packaging within a re-use system and the corresponding non-reusable packaging denominator.
- 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.

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 calculation, methodology, demonstration, first reporting year, and competent-authority reporting records.
- [Register of delegated and implementing acts](https://webgate.ec.europa.eu/regdel/?ref=sorena.io) - European Commission register for tracking delegated and implementing acts that may specify PPWR calculation, pooling, or exemption details.

*Recommended next step*

*Placement: after evidence section*

## Turn PPWR reuse applicability into a reporting file

Map each packaging flow to the correct Article 29, 32, or 33 branch before teams calculate targets, publish reuse claims, or prepare competent-authority reporting.

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

## 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, Article 33 reusable offers, and Annex VI reuse/refill system requirements.
  - 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 PPWR reuse, refill, collection, and mid-2026 application context.
  - Quote: "Packaging & Packaging Waste Regulation"
- [Register of delegated and implementing acts](https://webgate.ec.europa.eu/regdel/?ref=sorena.io) - European Commission register for monitoring future PPWR implementing and delegated acts relevant to Article 29 calculation, pooling, and exemptions.
  - Quote: "delegated and implementing acts"

## 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 and refill targets: Article 29 and take-away duties](/artifacts/eu/packaging-waste-regulation/reuse-and-refill-targets.md): source-linked guide to PPWR reuse targets for transport, grouped, beverage, and take-away packaging, including Article 29, 32, 33, reporting, and exemptions.
- [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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