Does the PPWR apply to B2B? Transport packaging, pallets, stretch film, strapping and used cartons

The short answer: yes. The EU Packaging Regulation recognises no exemption for trade between businesses. Under Article 3(1)(1), packaging is any item intended to be used for the containment, protection, handling, delivery or presentation of products "to another economic operator or to an end user". The pallet that carries your machine to the customer, the stretch film around it and the strapping band over it are packaging within the meaning of the Regulation, and the Commission has expressly stated in its FAQ that transport packaging is exempt neither from the conformity assessment nor from the declaration of conformity.

The long answer is more interesting, because which obligations apply, who bears them and from when differs considerably between pallet, film, shipping carton and reusable box. This article goes through the transport packaging of everyday industrial practice one by one, clarifies the manufacturer and producer roles for each packaging type, shows what has applied since 12 August 2026 and what is only coming in 2028 and 2030, and answers the question about used cartons. At the end there is a checklist to download.

Does the PPWR also apply to B2B packaging?

Yes, and it does so for all packaging types. The Regulation distinguishes between sales packaging, grouped packaging, transport packaging, service packaging and primary production packaging. Under Article 3(1)(7), transport packaging is packaging that facilitates the handling and transport of sales units and prevents damage, with a single exception: road, rail, ship and air containers are excluded from the definition. Everything below that is covered, from the euro pallet through pallet collars, boxes, slatted crates, drums, canisters and intermediate bulk containers (IBC) to stretch film, shrink hoods, strapping band, edge protectors, interlayers, filling material and adhesive tape.

A special form is e-commerce packaging: transport packaging used for delivery to end users in distance sales (Article 3(1)(8)). The end user here is not only the consumer but also the professional end user, in other words any company that does not distribute the product onward in the same form. The shipping carton in which a tool dealer sends a drill to a craft business is therefore e-commerce packaging. As shown below, this has tangible consequences in Germany.

What the Regulation does not cover: items that merely enable the manufacturing process. In its guidance, the Commission cites adhesive process films on semi-finished products and plant pots within the growing cycle as examples. Whether an item is packaging is always decided by the definition, not by the indicative list in Annex I.

Which obligations have applied to transport packaging since 12 August 2026?

The same basic obligations apply to transport packaging as to every other packaging, with some exemptions that relieve B2B companies and some special features that burden them.

What applies: The substance requirements of Article 5, that is the minimisation of substances of concern and the limit of 100 mg/kg for lead, cadmium, mercury and chromium VI together, apply to every transport packaging. The PFAS limits apply only in the case of food contact, which is rare for transport packaging but possible for flexible formats for loose food. General recyclability under Article 6(1) applies at the level of the previous Packaging Directive. For reusable transport packaging, that is reusable pallets, plastic boxes, crates, drums and intermediate bulk containers (IBC) in circulation, the requirements of Article 11 on reusability apply. Anyone making them available for the first time in a Member State must ensure that a reuse system under Annex VI exists there (Article 26), and anyone using them participates in such a system and ensures reconditioning (Article 27). Existing systems are considered sufficient. Every transport packaging needs a type, batch or serial number as well as the name and address of the manufacturer (Article 15(5) and (6)), if need be in the accompanying documents where affixing is not possible. Every packaging type undergoes the conformity assessment under Module A and receives a declaration of conformity under Annex VIII (Articles 38 and 39). And all economic operators document under Article 22 from whom they obtain packaging and to whom they supply it.

What does not apply: The harmonised sorting labelling under Article 12(1), which arrives from 2028, expressly does not apply to transport packaging. The only exception to the exception is e-commerce packaging, which must be labelled like sales packaging. The labelling of reusable packaging under Article 12(2) arrives from 12 February 2029 or 30 months after the associated implementing act, and the Commission has clarified that reusable transport packaging placed on the market before 11 February 2025 may remain in circulation until it leaves the system. Custom-made transport packaging for configurable medical devices and systems is exempt from conformity assessment and technical documentation under Article 15(11).

What comes in 2030: The empty space ratio of at most 50 per cent for grouped packaging, transport packaging and e-commerce packaging (Article 24), with filling material counting as empty space. The reuse targets of Article 29 for pallets, boxes, crates, intermediate bulk containers, drums, canisters and the associated wrappings and strapping bands. Packaging minimisation under Article 10. And the performance grades for recyclability under Article 6(2).

Who is the manufacturer for pallets, film, strapping and cartons?

The manufacturer is responsible for conformity, draws up the technical documentation and issues the declaration of conformity. For transport packaging, according to the Commission FAQ the manufacturer question is answered in the empty state, and the Central Agency Packaging Register (Zentrale Stelle Verpackungsregister, ZSVR) has introduced a distinction here that shapes everyday practice: dimensionally stable or flexible.

Dimensionally stable transport packaging such as pallets, pallet collars, boxes, crates and drums receives its final shape during production. The manufacturer is the maker of the empty packaging. Anyone buying a neutral euro pallet obtains the declaration of conformity from the pallet manufacturer and does not issue one of their own.

Flexible transport packaging such as stretch film on the roll, shrink hoods and strapping bands receives its final shape only when it is applied. On the ZSVR's reading, the manufacturer is therefore whoever assembles the packaging with all its components, in other words the company that wraps and straps the pallet. The Commission takes a different view in its FAQ of August 2026: unprinted stretch film, it says, is already placed on the market as packaging while still on the roll, and the manufacturer is the film manufacturer, not the company that buys the film and secures loads with it. The two readings stand side by side, and the market surveillance authorities of the federal states have not yet committed themselves. The safe course is therefore to have both: obtain the declaration of conformity and the substance data of the film and strapping manufacturer under Article 16, and additionally document the wrapped unit with all its components yourself, so that on either reading you can demonstrate what you use.

Cartons are the most difficult case, because the same carton can be sales, grouped, transport or e-commerce packaging depending on its use. For the shipping carton, the ZSVR has described three constellations. Anyone who has a carton made with their own name or logo is the manufacturer. Anyone who uses a neutral carton that is supplied as a complete packaging, such as a mailing bag with an integrated adhesive strip, is not the manufacturer as long as they do not modify the packaging. But anyone who first assembles carton, adhesive tape and filling material into the finished shipping packaging is the manufacturer of that packaging, because it only comes into being through them. And anyone who adds something to a complete packaging that could affect its recyclability is considered the manufacturer under Article 21. An ordinary shipping label is not such an addition: the Commission has made clear in its FAQ that a sticker for shipping is not a trademark and does not make the sender the manufacturer.

Added to this are the rules from Manufacturer or producer? Which role your company has under the PPWR: if the transport packaging bears the name or trademark of the customer, the customer is the manufacturer. If the commissioning party is a microenterprise with a supplier in the same Member State, the supplier is the manufacturer.

The practical consequence: a wrapped pallet with goods is not one packaging but several. According to the Commission FAQ, pallet, pallet collar, wrapping and strapping band are different packaging types that are assessed separately and need separate declarations of conformity. For the pallet and the collar you obtain the declaration. For the film and the strapping you obtain the manufacturer's declaration and additionally document the wrapped unit yourself, as long as the Commission and the ZSVR determine the manufacturer differently.

Overview by packaging type:

How to issue the declaration is set out in PPWR declaration of conformity: template, mandatory content under Annex VIII and instructions. One point from it is particularly relevant for transport packaging: for 2026 the declaration only has to cover the requirements that apply today. Empty space, reuse targets and recyclability grades do not yet belong in it.

Who is the producer in B2B, and what does that mean in Germany?

The producer role, that is the extended producer responsibility, is determined per Member State according to the domestic-first principle: the producer is whoever opens the supply chain in the country where the packaging becomes waste. A special rule applies to transport packaging, one that the Commission expressly describes in its guidance document. If it is made available for the first time in a Member State other than the one in which its manufacturer is established, the manufacturer is only the producer if the recipient is the end user of the packaged product. If the recipient is a company that distributes the goods onward, that company is itself the producer.

For industrial companies this means: anyone who delivers plants, components or semi-finished products directly to end customers in other Member States is the producer of their transport packaging there and must appoint an authorised representative for extended producer responsibility there (Article 45(3)). Anyone who delivers to dealers or further processors leaves the producer role to the recipient.

In Germany, four obligations for producers of transport packaging arise from the Packaging Implementation Act.

First, registration in the LUCID packaging register, which applies to all packaging types, including pure transport packaging, and must take place before the first making available (Section 6 VerpackDG). Anyone who was registered under the German Packaging Act remains registered; changes must be added by 12 November 2026.

Second, take-back. Under Section 3(6) VerpackDG, packaging is subject to system participation only if, measured against the total market of packaging of the same type, it typically ends up as waste mainly in private households or comparable sources of waste. Pallets, films and industrial cartons do not. Instead, producers and subsequent distributors must take back used, completely emptied transport packaging of the same kind, shape and size free of charge at the place of handover and recover it (Section 39 VerpackDG). With commercial end users, differing agreements on the place of return and the costs may be made, and for recurring deliveries the take-back can take place with the next delivery. The quantities taken back and recovered must be documented annually by 15 May, broken down by material type and mass.

Third, and this is new: for packaging not subject to system participation, in other words precisely for transport packaging, the VerpackDG introduces an authorisation of the producer by the ZSVR (Section 19 VerpackDG, on the basis of Article 47 of the Regulation). The authorisation requires, among other things, an insolvency-proof security, self-control mechanisms and a financing agreement, or the transfer of the obligations to an authorised other producer responsibility organisation. The ZSVR expects its electronic application systems in autumn 2027, the transition period runs under Section 68(9) until 31 December 2027, and from 1 January 2028 the authorisation is mandatory. Distributors are affected too: they may then no longer make such packaging available if the producer neither is authorised nor has commissioned an authorised organisation (Section 11(3) VerpackDG). Anyone who places a lot of transport packaging on the market should have this topic on the agenda in 2027.

Fourth, the exception to the exception: in the view of the ZSVR, packaging for shipping to end users is subject to system participation without exception, because under the PPWR it must be considered independently of the product shipped, and Section 3(6) VerpackDG expressly refers to the total market of packaging of the same type, not to the individual recipient. That includes shipping packaging to commercial and industrial end users. So anyone who sends spare parts in a shipping carton to workshops must arrange system participation for these cartons with a dual system, even if no consumer ever handles them. The details of the relationship between the Regulation and German law are set out in PPWR, VerpackG, VerpackDG and LUCID: what applies when.

What applies to used cartons?

The question comes from two directions: May I reuse the cartons in which my supplier delivered goods to me for my own shipping, and what do I then have to do? The Regulation does not expressly regulate the second use of single use packaging, so the answer has to be derived from the general rules, and under the old German Packaging Act the ZSVR developed a practice on this point that continues to apply.

For conformity the position is this: whoever takes a used carton, seals it with new adhesive tape and adds filling material is, according to the logic of the ZSVR, assembling a packaging and is the manufacturer of that packaging, with technical documentation and declaration of conformity. For used cartons of varying origin this is hardly feasible, because the substance data for the carton are missing. Anyone who uses used cartons systematically should therefore restrict themselves to a few known carton types for which the original supplier can provide data.

For extended producer responsibility the position is this: used packaging is not generally exempt. Under the practice of the ZSVR, the user of used packaging material must be able to demonstrate that the packaging has already participated in a system. If the carton was previously transport packaging in the commercial sector, it was registered but did not participate in a system. If it is now used for the first time as shipping packaging to end users, the user is responsible for system participation.

This must be distinguished from reuse within the meaning of the Regulation: reusable packaging designed to accomplish multiple rotations, in a reuse system under Annex VI. A used single use carton does not become reusable packaging through its second use and does not count towards the reuse targets.

The 2030 reuse targets: what logistics should plan for now

Article 29 is the part of the Regulation that will change B2B logistics the most. From 1 January 2030, economic operators using transport packaging in the form of pallets, foldable plastic boxes, boxes, trays, plastic crates, intermediate bulk containers (IBC), pails, drums and canisters, including the flexible formats, pallet wrappings and strapping bands, must ensure that at least 40 per cent of this packaging is reusable within a reuse system. From 2040 the figure is to be 70 per cent.

Two paragraphs tighten this for internal transport: for transports between a company's own sites and to linked enterprises within the EU, and for deliveries to other economic operators within the same Member State, this packaging must be entirely reusable from 2030 (paragraphs 2 and 3).

Four exemptions relieve industry (paragraph 4): packaging for the transport of dangerous goods, packaging for large machinery, equipment and raw materials designed to the individual requirements of the commissioning party, flexible formats in direct contact with food and feed, and boxes made of cardboard or paperboard. The Commission has added that the targets lie with the recipient of the transport packaging, that is with whoever uses it, and that for imports they apply from the first warehouse in the EU, not to the sea transport on the way there.

The Commission will lay down the calculation method by 30 June 2027; the obligation to demonstrate compliance starts in 2030 or 18 months after that legal act (Article 30). Anyone who records their transport packaging today and sorts it by format, single use or reusable, and destination region will know in 2027 how far they are from 40 per cent. More detail on empty space and minimisation: Recyclability, recycled content, empty space and packaging minimisation.

Wooden pallets and the EUDR: two regulations, one pallet

Anyone working with wooden pallets encounters not only the PPWR but also the Deforestation Regulation, and the distinction is simpler than it sounds. According to the Commission's EUDR FAQ, packaging material that is used exclusively to support, protect or carry another product does not fall within the scope of the EUDR, regardless of the customs tariff number. The pallet under your machine is EUDR-free. If, on the other hand, the pallet is placed on the market as a product in its own right, for instance sold to you by the pallet manufacturer, it is subject to the EUDR under heading 4415, and the pallet manufacturer needs a due diligence statement for it. Reselling or renting out pallets that have already been used is also EUDR-free.

The PPWR takes an interest in the same pallet from the other direction: substance limits, identification, the pallet manufacturer's declaration of conformity, reusability under Article 11, take-back under Section 39 VerpackDG. What both regulations need in common are supplier master data, material information and a clean assignment of which packaging comes from which supplier. More on this in Implementing the EUDR and PPWR together and Which products and customs tariff numbers fall under the EUDR.

The most common mistakes in B2B

1. Treating B2B as an exception. The Regulation applies to the pallet just as it does to sales packaging. There is no de minimis threshold.
2. Assessing the pallet as one packaging. Pallet, film and strapping are separate packaging types with separate declarations and in some cases different manufacturers.
3. Using film and strapping without evidence. It is an open question whether the film manufacturer (Commission) or you (ZSVR) are the manufacturer. Without the manufacturer's declaration and without documentation of your own, you are poorly placed on both readings.
4. Not licensing shipping cartons sent to business customers. In the view of the ZSVR, shipping packaging supplied to commercial end users is subject to system participation.
5. Cross-border direct deliveries without an authorised representative. Anyone delivering to end customers in other EU countries is the producer of their transport packaging there.
6. Overlooking the 2028 authorisation. From 1 January 2028, producers of packaging not subject to system participation need either an authorisation from the ZSVR or an authorised organisation.
7. Planning the reuse targets only in 2029. The 40 per cent cannot be managed without a stocktake, and pool systems need lead time.

How to proceed in practice

1. Record your transport packaging. Every packaging type individually: pallets by type, pallet collars, films, strapping bands, cartons by format, filling material, adhesive tape, reusable containers. With supplier, material, weight and use.

2. Clarify the manufacturer role for each packaging type. Dimensionally stable or flexible, branded or neutral, delivered complete or assembled by you. From this follows: obtain or issue.

3. Organise the evidence. Obtain declarations of conformity from the pallet, carton, film and strapping manufacturers, plus the substance data for each component with a basis of evidence. A standardised letter speeds this up, see template letter to upstream suppliers.

4. Issue your own declarations and document the units. For assembled shipping cartons and everything bearing your own logo, a declaration of your own for each packaging type with technical documentation under Annex VII. For the wrapped pallet, at least your own documentation of the unit with all components and the manufacturers' declarations as annexes.

5. Clarify the producer role for each target market. Where do you deliver, to whom, and who opens the supply chain there? From this follow registrations, authorised representatives and the German take-back and authorisation obligation.

6. Prepare for 2030. Determine the share of reusable transport packaging, measure the empty space per shipping unit, examine pool systems.

How Polygon One helps

Polygon One treats each packaging type as a packaging unit of its own with its components. The wrapped pallet is mapped the way the Regulation sees it: pallet, film and strapping as separate units, each with a role of its own. For the pallet you set the role of distributor or importer and collect the manufacturer's declaration via the supplier portal. For film and strapping you can cover both readings: collect the manufacturers' declarations and create the wrapped unit as a packaging unit of its own with all components and substance data, from which you generate the technical documentation and, if you follow the ZSVR reading, also the declaration of conformity, for a hundred units with one signature when the evidence is complete.

The target markets per unit determine in which Member States the platform shows a registration obligation, and the volume data per material type can be exported for volume reporting in Germany. What the platform does not do: assess the role assignment legally, organise the take-back under Section 39 or apply to the ZSVR for the authorisation. It holds the data in such a way that you can do this yourself with little effort.

If you would like to see how your transport packaging looks in this structure, book a demo or read more on the product page for the PPWR module.

Download the checklist

The checklist brings together the packaging types of everyday B2B business with the manufacturer role, declaration of conformity, substance obligations, German specifics and the requirements from 2030 in one table, and contains the six review steps as a worksheet.

• Download: PPWR checklist for transport packaging (DOCX)

Frequently asked questions

Does the PPWR also apply to B2B packaging?

Yes, without exception. Packaging is anything intended to be supplied to another economic operator or end user. Transport packaging needs a conformity assessment and a declaration of conformity like any other packaging.

What does the PPWR mean for transport packaging?

Since 12 August 2026, substance limits, identification and manufacturer details, a declaration of conformity per packaging type and traceability. From 2030, an empty space ratio of at most 50 per cent and reuse targets of 40 per cent, 100 per cent for internal and domestic transport.

Do euro pallets need a declaration of conformity?

Yes. The manufacturer is the pallet manufacturer, from whom you obtain the declaration. If the pallet bears your logo, you are the manufacturer.

Who issues the declaration of conformity for stretch film?

The interpretation is currently not uniform. In its FAQ, the Commission regards the film manufacturer as the manufacturer, because the film is already packaging while still on the roll. The ZSVR regards whoever applies the film as the manufacturer. Obtain the manufacturer's declaration and additionally document your wrapped unit yourself.

Is transport packaging exempt from the labelling obligation?

From the harmonised sorting labelling under Article 12(1), yes, with the exception of e-commerce packaging. The identification plus the name and address of the manufacturer under Article 15 must still be affixed.

Do I have to license shipping cartons sent to business customers in Germany?

In the view of the Central Agency Packaging Register, yes. Shipping packaging supplied to end users is subject to system participation, even if the end user is a company.

May I reuse used cartons for shipping?

Yes, but you take on the responsibility: whoever assembles the carton with tape and filling material is the manufacturer under the logic of the ZSVR, and without proof of an earlier system participation you are responsible for licensing in Germany.

Do wooden pallets fall under the EUDR?

Not as packaging under another product. As a product sold in its own right, yes, and the pallet manufacturer then needs a due diligence statement.

Sources and status: Regulation (EU) 2025/40 (OJ L, 22.1.2025), Articles 3, 5, 6, 10 to 12, 15, 16, 21, 22, 24, 26, 27, 29, 30, 38, 39, 45. Commission guidance document C/2026/3702, sections 1 to 3, 11, 12, 14, 18 to 21. Commission FAQ on the PPWR, 2nd edition (August 2026), sections II, X and XV. Packaging Implementation Act, Federal Law Gazette 2026 I No 207, Sections 3, 6, 7, 11, 19, 39, 66, 68. Central Agency Packaging Register, topic pages on the distinction between manufacturer and producer, mail order and online retail, and the authorisation procedure (as of 12 August 2026). EUDR FAQ version 5 (4 May 2026), questions 2.5 and 2.6. This article describes the legal position as of September 2026 and does not replace legal advice.