EU PPWR FAQs Updated August 2026 - Flipbook - Page 49
XIII.
REUSE AND REFILL
Reusable packaging (Article 11)
1) How will the rotations or trips of reusable packaging be calculated?
Reusable packaging must be designed to ensure a minimum number of rotations, which will be
established in the delegated act to be adopted under Article 11(2). The obligation to calculate and
report on the number of rotations for reusable transport packaging will depend on the type of reuse
system. In particular, open-loop reuse systems without a system operator are exempted from this
obligation (Annex VI, Part A, section 1 (i)). Closed-loop reuse systems with system operators must
report on the number of rotations or trips for each individual reusable packaging, or for an average
estimation if the calculation for each individual reusable packaging is not feasible.
The detailed rules on the calculation of the achievement of the re-use targets contained Article 30
will be clarified in the implementing act to be adopted under Article 12(6). This act will also specify
the situations where it is considered that an individual QR code and tracking of rotations is not
feasible and the calculation of rotations can be made based on an average estimation.
Manufacturers need to demonstrate that the design of reusable packaging and the related system
for reuse allow packaging to comply with the minimum number of rotations requirement. This will
need to be done at the time of placing packaging or a packaged product on the market in the
technical documentation and applies both to reusable packaging circulating in open loop and closed
loop reuse systems.
According to Article 27 and Annex VI, reuse systems must be designed to ensure that reusable
packaging rotating within them completes at least the minimum intended number of rotations as
set out in the delegated act. This will be verified by the Member States9 market surveillance
authorities (Article 62(1), point (h)).
Reuse systems
2) What is an 8open loop9 reuse system and what are some concrete examples of such
systems?
Open loop reuse systems are characterised by interoperability where reusable packaging can
circulate across different companies, locations, product categories, or sectors rather than being
returned to the single system operator. Open loop reuse systems do not necessarily mean that
reusable packaging becomes the property of the consumer once paid for; this will depend on the
business model. Such reuse systems are normally characterised by using standardised packaging,
shared infrastructure (e.g. for collection, washing and redistribution), and are often coordinated by
a system operator, who manages the logistics and ensures quality, even if the existence of a system
operator is not a legal requirement under the PPWR.
Under the PPWR, open-loop systems without a system operator are exempted from the reuse
labelling requirements and from the reporting on the number of rotations achieved.
Examples of open loop systems without a system operator are the following:
The 0.33-liter longneck reusable bottle system (in Germany): this system is mostly used by brewers,
but also by mineral water companies and other carbonated soft drink producers. Although there is
a standard for the bottle issued by the German Brewers Association and a licensing system for
participants, there is no system operator.
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