EU PPWR FAQs Updated August 2026 - Flipbook - Page 51
Article 29(4)(c) excludes from the targets transport packaging flexible packaging formats that are
used for transportation and that are in direct contact with food and feed, as defined in Article 2 and
in Article 3, point (4), of Regulation (EC) No 178/2002 or with food ingredients as defined in
Article 2(2), point (f), of Regulation (EU) No 1169/201.
Therefore, all flexible formats, such as big bags or flexible intermediate bulk containers, as listed
in Article 29(1), which are not used for direct contact with food and feed, and also not used for the
transportation of dangerous goods (exemption envisaged under Article 29(4)(d)), and not customdesigned for the transportation of large-scale machinery (exemption envisaged under Article
29(4)((b)) should comply with the reuse targets set forth in Article 29(1) to (3).
These will be further specified in the context of the Implementing Act under Article 30 on the rules
on the calculation of the achievement of the re-use targets.
8) Do 8pallet wrappings and straps9 count as one format or two separate formats?
Pallet wrappings and straps are different packaging formats, but they may be part of the same
transport unit for the purpose of calculating compliance with reuse targets under Article 29. This
will be further clarified in the implementing act under Article 30 on the rules on the calculation of
the achievement of the re-use targets.
9) If a format is not indicated in Article 29(1), can it still be in the scope of the reuse
targets for transport packaging? Are all flexible packaging formats, such as sealed
bags, in that scope or only those formats listed in paragraph 1?
Article 29(1) lays down an exhaustive list of packaging formats covered by reuse targets, including
their flexible formats. If a sealed bag is an intermediate bulk container, it is within the scope of the
reuse targets, unless it is in direct contact with food and feed, as specified in Article 29(4)(c), in
which case it is exempted.
10) What is the definition of a transport unit?
The term is not defined nor used in the Regulation, but it might be defined in the future for the
purpose of the rules on the calculation of the achievement of the re-use targets in the implementing
act to be adopted under Article 30(3).
Reuse targets for beverages
11) Do the reuse targets for beverages apply to non-alcoholic and alcoholic beverages
individually considered or are they joint targets?
The reuse target for beverages provided for in Article 29(6) applies to both alcoholic and nonalcoholic beverages. Final distributors, such as retailers, bars and restaurants, can decide what type
of beverages (alcoholic, non-alcoholic or both) they offer for sale to consumers in reusable
packaging in order to fulfil the reuse target. Final distributors shall, however, ensure that beverages
of their own brand contribute on a fair and proportionate basis towards the achievement of the reuse
target.
12) What beverages fall under the scope of the reuse targets for beverages?
The beverages within the scope of the reuse targets for beverages in Article 29(6) will be clarified
in Commission guidelines to be adopted by 12 February 2027. The guidelines will be developed in
consultation with the Member States and other relevant stakeholders.
Article 29(7) specifies that certain beverages are exempted from the reuse targets. This includes:
48
