Commission’s interpretation:
It is necessary to distinguish between: reusable transport packaging placed on the market before the entry into force of the PPWR, i.e. before 11 February 2025 and reusable transport packaging placed on the market after 11 February 2025 (i.e., after the entry into force of the PPWR) but before the date of application of the implementing act on labelling for reusable packaging, which should be adopted by 12 August 2026 and apply from 12 February 2029 or 30 months from the date of entry into force of the implementing act, i.e., reusable transport packaging placed on the market between 11 February 2025 and 12 February 2029. Reusable packaging under (a) may remain in circulation until it is removed from the re-use systems due to functional obsolescence or operational limitations. Reusable packaging under (b) should comply with the labelling requirements at the latest by February 2032. Considering that the new labelling rules will be known by the industry already at the time of the adoption of the implementing act, i.e. in August 2026, a limited amount of reusable transport packaging will need to be brought into compliance. In practice, packaging that will be placed on the market during the period between February 2025 and August 2026 will have to be refurbished with labels according to the new rules by February 2032. It should be recalled that after the entry into force of the PPWR, operators no longer have legitimate expectations to not being subject to the new labelling rules. The conditions of Article 12(5) warranting the provision of information via websites or accompanying documentation are met in the case of reusable transport packaging in a business-to-business situations (i.e. consumer not being the end user of the transport packaging), managed by a system operator in a closed-loop system.
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Source: EUR-Lex (Cellar) · retrieved 2026-09-07 · Text as adopted (Official Journal); later amendments are not incorporated in this text.