The European Commission has sought to allay industry fears over the practical feasibility of new labelling requirements for reusable secondary and tertiary packaging under the Packaging and Packaging Waste Regulation (PPWR), stressing that existing packaging will not need to be retrofitted or withdrawn before 2032 and that implementing acts will take account of proportionality and technical feasibility.
In a written answer on 10 July 2026 to a parliamentary question led by MEP Stefan Köhler (EPP), Environment Commissioner Jessika Roswall acknowledged the challenges raised by MEPs regarding Articles 12 and 15(8) of the PPWR. The MEPs had warned that the rules, which apply to packaging placed on the market after 12 February 2025, could effectively require retrofitting or withdrawal of large volumes of crates and pallets currently in circulation, as automated systems cannot distinguish pre- and post-cut-off packaging.
Roswall pointed to the Commission's guidance document of 30 March 2026, which clarifies that reusable transport packaging placed on the market before 11 February 2025 does not need to be withdrawn or retrofitted. Packaging placed after that date but before the application of new labelling requirements will only need to comply by 2032, after all transitional periods have expired. Packaging in open-loop reuse systems is exempted from labelling requirements altogether.
For closed-loop business-to-business systems managed by a system operator, the guidance confirms that information can be provided via websites or accompanying documentation rather than physical labels. The Commission committed to taking account of proportionality, technical feasibility and the need to avoid unnecessary administrative or economic burdens when preparing implementing acts under Article 12. Roswall also pledged continued engagement with stakeholders and Member States to ensure pragmatic and harmonised implementation, including appropriate transitional approaches where justified.
The answer signals a flexible, industry-friendly approach that seeks to protect well-functioning reuse systems from disruption, while maintaining the PPWR's circular economy objectives. The Commission's implementing acts, expected in the coming months, will be the key test of how far this flexibility translates into concrete derogations or transitional arrangements for existing packaging.
--- Stakeholder impact: The answer provides regulatory relief for logistics and retail sectors relying on reusable crates and pallets, avoiding immediate retrofitting costs. EU producers of reusable packaging benefit from continued use of existing stock. Environmental NGOs may see the extended timeline as a delay in achieving circularity goals. National authorities face complexity in enforcing labelling rules across mixed packaging pools.