EU PPWR FAQs Updated August 2026 - Flipbook - Page 50
The Euro Pallet: this system has a standard for the pallets, and licensees for production are issued,
but there is no system operator or system management, even though an association (i.e., EPAL) is
responsible for licensing and some other services.
3) How can economic operators using reusable packaging ensure that a proper reuse
system is in place?
According to Article 27 PPWR, economic operators using reusable packaging must participate in
one or more re-use systems and ensure that these systems comply with the requirements laid down
in the PPWR, Part A of Annex VI. Economic operators also have the possibility to set up their own
re-use system, which must comply with Annex VI. The PPWR establishes the minimum
requirements for the reuse systems in its Annex VI, and the sector needs to find ways to cooperate
and find the most appropriate solutions, depending on their respective products and the local
circumstances, to optimise the functioning of the reuse system.
4) Does a reuse system need to be open for all end users?
Re-use systems can vary in size and geographical coverage and range from smaller local systems
to larger systems that may span over one or several Member States9 territory. Reuse systems do not
have to cover the entire MS. They must however provide equal access and fair conditions to the
end users in the area in which they operate.
5) Are reuse systems obliged to carry out extended producer responsibility on behalf of
the producers participating in the reuse system? NEW!
Extended producer responsibility (EPR) obligations apply to all producers who place packaging on
the Union market, whether it is single-use or reusable.
While the EPR obligation remains with the producer of the reusable packaging, the reuse system
must have in place procedures to ensure that EPR obligations are implemented for the reusable
packaging that is part of the system, as specified in Annex VI, Part A, point 1(i) of the PPWR.
The provision in Annex VI should be viewed in the context of how re-use systems are organised.
In open loop systems, which do not have a system operator, the reusable packaging circulates
among an unspecified number of participants as explained in the Commission notice, point 2.
Therefore, there may be more than one producer with corresponding EPR-obligations participating
in the reuse system. In open loop systems where the re-use system operator is often the
manufacturer, there is only one producer responsible for complying with EPR obligations.
It will be at the discretion of the producer to determine how to fulfil its EPR obligations, insofar as
the Member State has not laid down specified rules.
Reuse targets for transport packaging
6) Would the exemption for cardboard boxes from the reuse targets for transport
packaging cover interlayers and corrugated cardboard?
Article 29(4)(d) exempts cardboard boxes from the scope of the reuse targets. This should be
understood as including corrugated cardboard boxes. However, the list of exemptions contained in
Article 29(4) must be understood strictly and is limitative, in terms of material, format and use.
Therefore, the exemption of cardboard refers only to cardboard boxes and does not include
interlayers. Nevertheless, since they are also not a format that is explicitly listed in Article 29(1)
and therefore, interlayers are also not concerned by the reuse targets in the first place.
7) What packaging formats are covered by the exemption for flexible formats for
transport packaging?
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