Are your suppliers ready for the new EU packaging rules?

On 25 February 2026, the European Commission adopted a Delegated Act that exempts wrapping and straps used to secure goods on pallets during transport from the EU’s 100% reuse requirement [2]. Following the scrutiny period and publication in the Official Journal, the exemption has since entered into force. The exemption brings immediate relief to building materials merchants across Europe. Previously, the Packaging and Packaging Waste Regulation (PPWR) set a strict 100% reuse target for pallet wrapping and straps by 2030 when used within companies and between companies in the same Member State [2]. For a yard handling heavy, irregular building materials like roof tiles, bricks, or timber bags, the physical reality of securing these loads requires high-tension wrapping that is rarely reusable in a closed loop. While this 100% requirement was dropped, these materials still remain within the scope of the overall reuse targets [2].

This relief does not mean traders can ignore the broader regulatory shift. The legal anchor for these changes is Regulation (EU) 2025/40 of the European Parliament and of the Council on packaging and packaging waste, which was signed on 19 December 2024 [1] and entered into force on 11 February 2025 [2, 3]. The scheduled application date for the regulation is 12 August 2026 [1, 3, 4]. This regulation applies broadly to all businesses placing packaging on the EU market, including manufacturers, importers, distributors, and retailers [3]. It covers all packaging types, including primary, secondary, tertiary, and service packaging [3]. For those sitting in the middle of the supply chain, immediate action is required to map out compliance before the first wave of obligations takes effect.

The 25 February 2026 Delegated Act specifically addresses the stretch wrap around a load of roof tiles and the plastic strapping holding bricks together [2]. Under the original text of the PPWR, these securing materials were subject to a 100% reuse requirement by 2030 for internal and same-Member-State transport [2]. The European Commission’s decision to exempt these materials recognizes that single-use plastic stretch wrap and metal or plastic strapping are essential for transport safety and cannot easily be replaced by reusable alternatives [2].

While these wrapping and strap materials are exempted from the 100% reuse requirement, they remain within the scope of the overall transport packaging rules [2]. This means businesses must still track their use and ensure they are managed responsibly. The exemption is a pragmatic concession, but the broader push toward circularity remains intact. The European Union will continue to develop and work out the PPWR over the coming years, with further rules scheduled to be introduced up to and including 2029 [4]. This phased rollout means that requirements will continue to evolve, requiring continuous monitoring from commercial and procurement directors.

The first major milestone for the industry occurs on 12 August 2026, when the first obligations of the PPWR start to apply [4]. By this 12 August 2026 deadline, packaging manufacturers must have completed a conformity assessment and drafted a conformity statement [4]. This requirement is designed to ensure that all packaging placed on the market meets the strict environmental and safety standards set by the EU.

For distributors, this deadline represents a significant supply chain risk. If a manufacturer fails to complete its conformity assessment and draft the conformity statement by the 12 August 2026 deadline, the packaging they use becomes technically non-compliant [4]. While the physical building material inside the packaging, such as the cement in a bag or the bricks on a pallet, remains perfectly sound, placing non-compliant packaging on the market is a regulatory violation. Businesses may face restrictions on making non-compliant packaging available on the market, leading to stock shortages and supply chain disruptions [4].

To navigate these new requirements, the PPWR requires businesses to determine their role or roles in the packaging chain [4]. This role designation is critical because it dictates which specific rules a business must comply with [4]. A merchant might act as a distributor when selling packaged goods, but they could be classified as an importer if they bring packaged materials directly into the EU from non-EU countries. That distinction determines which obligations apply. If a business is classified as an importer, it may bear direct responsibility for ensuring that the packaging of the goods it imports complies with all EU standards, whereas a distributor’s obligations focus more on verifying that the packaging has already been certified by the manufacturer.

While the primary legal obligations are defined in the official EU texts [1, 2], secondary-source guidance from non-EU jurisdictions, such as the UK government’s summary, last updated 21 May 2026, highlights that the regulation applies broadly to all businesses placing packaging on the EU market, including manufacturers, importers, distributors, and retailers [3]. The same secondary guidance notes that the rules cover all packaging types, including primary, secondary, tertiary, and service packaging [3].

In a merchant’s yard, primary packaging includes the plastic bags containing dry-mix mortar or the cardboard boxes holding individual plumbing fixtures. Secondary packaging refers to the grouping boxes that hold multiple retail units together. Tertiary packaging encompasses the heavy-duty transport packaging, such as the wooden pallets, plastic stretch wrap, and metal strapping used to secure bulk loads during transit. Because every single layer of this packaging hierarchy is subject to the regulation, distributors must ensure they understand their obligations for each type of packaging they handle.

Looking further ahead, the regulation establishes ambitious long-term targets that will force a transition in yard operations. From 1 January 2030, economic operators in the EU must ensure that at least 40% of transport and sales packaging is reusable [2]. This target specifically covers formats ubiquitous in the building trade, including pallets, foldable-plastic boxes, boxes, trays, plastic crates, intermediate bulk containers, pails, drums, and canisters [2].

This means that a substantial portion of the pallets or crates that enter your yard must be part of a reusable system. Transitioning to reusable formats represents a significant operational shift [2]. Reusable pallets and containers are designed to be used multiple times, but they require robust systems to ensure they are returned and reused. Consider the pallet that never comes back from a construction site. Under the new rules, merchants must track these assets and ensure they are returned to the reuse loop. This will require close cooperation with contractors and logistics partners to manage return logistics and inspect returned units for damage.

To prepare for the upcoming deadlines, procurement directors must take immediate action to secure their supply chains. The first step is to audit your suppliers to ensure they are on track to meet the 12 August 2026 deadline [4]. Procurement teams must verify that their manufacturing partners have completed the required conformity assessments and drafted conformity statements [4].

Contracts signed today should include explicit clauses requiring suppliers to guarantee compliance with Regulation (EU) 2025/40 [1]. Traders should demand copies of the drafted conformity statements [4] as part of their standard quality assurance processes. This proactive approach will help mitigate the risk of supply chain disruptions and ensure that only compliant packaging enters your warehouse.

At the same time, commercial directors should begin planning for the 1 January 2030 reuse targets [2]. This involves negotiating clear agreements with suppliers regarding who owns reusable assets, such as pallets and crates, and who is responsible for their loss or damage. It is critical to determine who bears the cost if a contractor fails to return a reusable pallet to the yard. Resolving these operational details now will protect your margins and ensure a smooth transition to a circular packaging economy.

[1] eur-lex.europa.eu — https://eur-lex.europa.eu/legal-content/NL/ALL/?uri=CELEX:32025R0040 [2] environment.ec.europa.eu — https://environment.ec.europa.eu/news/pallet-wrapping-straps-exempt-100-reuse-requirement-2026-02-25_en [3] business.gov.uk — https://www.business.gov.uk/campaign/europe/european-union-eu-regulations/eu-packaging-and-packaging-waste-regulation-eu-ppwr/ [4] business.gov.nl — https://business.gov.nl/amendments/ppwr-imposes-stricter-requirements-packaging/