What is transport packaging and what are my EPR obligations?

Transport packaging is tertiary packaging designed to facilitate the handling and transport of sales units to prevent damage during transit (Commission Notice - Guidance document for Regulation (EU) 2025/40 on packaging). Under Article 24(1) of the PPWR, transport packaging must be filled to at least 50% of its volume, with void fillers counted as empty space.

For businesses distributing goods, managing compliance across several borders can become an administrative burden. Pallets, shrink wrap, and strapping bands are often treated as back-of-house utility materials, yet environmental authorities increasingly include these materials in waste management fees. Correctly identifying transport packaging is the first step toward ensuring your supply chain remains fully compliant.

Navigating these regulations requires understanding how local and international laws define who is responsible for the packaging.

What transport packaging actually means

Transport packaging occupies the outer layer of the packaging hierarchy, designed primarily to prevent physical damage to goods as they move from factories to distribution hubs. Under Article 3(1) of the EU Packaging and Packaging Waste Regulation (PPWR), transport packaging - also referred to as tertiary packaging - excludes road, rail, ship, and air containers. The law distinguishes it from sales packaging, which is primary, and grouped packaging, which is secondary (Packaging and Packaging Waste Regulation (EU) 2025/40).

A key legal distinction under the PPWR relates to how transport packaging is treated when first placed on the market. Unlike primary and secondary packaging, which are typically declared when filled with products, transport packaging is often assessed as empty packaging. If the empty transport packaging does not bear a unique name or trademark, the entity that manufactures or imports the empty packaging is considered the producer. However, if the pallet or crate carries your specific brand name, your business becomes the producer.

Transport packaging must be declared at its point of first entry into a national market, with obligations falling on the manufacturer of the empty packaging or the brand owner who fills it.

In global jurisdictions, the classification focuses on where the waste accumulates. For instance, in Canadian provincial stewardship programmes, such as those in Manitoba and Ontario, transport packaging that is not intended primarily for use or management in the home - such as industrial plastic pallet wrap - is excluded from residential reporting (Multi-Material Stewardship Manitoba steward guidebook). However, if transport packaging is delivered directly to a consumer's home, as is the case with e-commerce shipping boxes, it enters the municipal waste stream and must be declared.

Does this apply to me?

Yes, if your business imports, distributes, or manufactures goods within a regulated market, transport packaging compliance applies to you. Under Article 3(15) of the PPWR, any economic operator who makes transport packaging available for the first time on a Member State's territory is legally defined as a producer. This includes importers shipping packaged goods into the EU, as well as domestic brands filling transport containers.

Logistics companies also face specific obligations under these frameworks. If your logistics company imports goods from third countries and conducts unpacking, repacking, or sorting activities, you are classified as the producer of the original transport packaging that stays in your facility. This holds true even if your company never takes ownership of the actual merchandise.

Furthermore, digital marketplaces are held responsible for verifying that their sellers comply with these requirements. If you sell products online, your platform must check that you are registered with the appropriate national registers before your goods can be listed for sale.

What reuse targets and deadlines apply to transport packaging under the PPWR?

The key dates carry reusable targets: the PPWR sets strict performance criteria for transport packaging on material reuse and empty space minimisation. These targets require businesses to adapt their logistics workflows well ahead of the implementation deadlines.

The table below details the specific regulatory timelines, reuse targets, and waste prevention goals established under current EU and national packaging laws.

The empty space rule under Article 24(1) requires that any operator filling transport packaging must ensure that at least 50% of the volume is filled with products, meaning void fillers like paper cuttings or air cushions are counted as empty space. Reusable transport packaging is exempt from this empty space limit.

The re-use targets under Article 29 apply to formats such as pallets, foldable plastic boxes, plastic crates, intermediate bulk containers, pails, drums, and canisters. However, Article 29(4)(d) explicitly exempts cardboard boxes from these reusable mandates, recognising that cardboard has a very low rotation lifespan.

Common misconceptions about transport packaging

“E-commerce boxes are classified as sales packaging”

This is a frequent mistake. Cardboard shipping boxes used to deliver items directly to a consumer's home are legally classified as e-commerce packaging, which is a subcategory of transport packaging. As a result, they are subject to transport packaging rules, though they are exempt from the 50% empty space ratio if they are reusable or act as sales packaging.

“Logistics providers do not have to pay EPR fees because they do not own the goods”

This is incorrect. Under Article 3(15)(e) of the PPWR, logistics companies that unpack imported goods from third countries are considered the producer of the original transport packaging that becomes waste at their facility.

“All plastic transport wrap must be 100% reusable by 2030”

This was a major concern for distributors. The European Commission clarified this rule on 25 February 2026 through a Delegated Act that exempts pallet wrapping and straps from the 100% reuse requirement due to disproportionate adaptation costs. They must still be counted toward the broader 40% target.

“If you only sell in B2B markets, you are exempt from packaging regulations”

This is false. EPR obligations cover both household and commercial packaging. While B2B packaging may follow different collection routes, you must still register with national registers and pay fees based on the total weight of the transport materials you put on the market.

5 examples of transport packaging

Standard wooden pallets

Multi-way timber structures used to stack, handle, and move products through the supply chain. Pallet hire systems can help meet the 40% reusability mandate.

Rigid plastic crates

Durable, stackable containers used to transport fresh fruit and vegetables to retail points. These crates are designed for multiple rotations within a closed-loop reuse system.

Steel drums and canisters

Industrial containers used to transport bulk liquids or chemicals. If custom-designed for a specific operator, they may be exempt from standard reuse targets.

Plastic stretch wrapping

Low-density polyethylene (LDPE) film wound around stacked pallets to stabilise and protect goods. This film must be reported under the flexible plastic category.

Corrugated shipping boxes

Multi-layered cardboard boxes used to protect grouped sales units during transport. These boxes are exempt from reusable targets under Article 29(4)(d).

Terms related to transport packaging

The table below lists key terms within the compliance framework that define neighbouring packaging categories.

Frequently asked questions

Do cardboard boxes have to meet the 40% reuse target under PPWR?

No, cardboard boxes are explicitly exempt from the re-use targets under Article 29(4)(d) of the PPWR. The exemption recognises that corrugated paper has a short lifespan and is better suited for high-quality recycling.

Who is considered the producer of an unbranded wooden pallet?

If the transport packaging is unbranded and ready to use, the actual manufacturer of the empty packaging is considered the producer. If the pallet carries your brand trademark, your business is responsible.

Are pallet strapping bands subject to the 100% reuse rule?

No, the European Commission adopted a Delegated Act on 25 February 2026 exempting pallet wrapping and straps from the 100% reuse requirement to avoid disproportionate industry costs.

How does Sweden regulate commercial transport packaging waste?

Under the Swedish Ordinance (2022:1274), all producers must join an approved Producer Responsibility Organisation (PRO) to finance the collection and recycling of both household and commercial packaging.

Do I have to declare empty transport packaging that I import?

Yes, if you are the first importer establishing empty transport packaging on a national market, you are classified as the producer and must report the material weights.

Is there a simplified declaration for small volumes of transport packaging?

Yes, several countries offer simplified reporting. For example, Verpact in the Netherlands provides a simplified reporting route for companies putting less than 10,000 kg of packaging on the market annually.

Sources:

• Commission Notice - Guidance document for Regulation (EU) 2025/40 on packaging
• Packaging and Packaging Waste Regulation (EU) 2025/40
• Multi-Material Stewardship Manitoba steward guidebook
• NATIONAL STEWARDS GUIDEBOOK - Multi-Material Stewardship Manitoba
• Pallet wrapping & straps exempt from 100% reuse requirement - EU Environment
• Everything you need to know about the PPWR - Verpact