§19 Re-use targets for transport packaging in international trade

Legal provisions: ‘(1) From 1 January 2030, economic operators that use transport packaging, or sales packaging used for transporting products, including for products distributed via e-commerce, within the territory of the Union, in the form of pallets, foldable-plastic boxes, boxes, trays, plastic crates, intermediate bulk containers, pails, drums and canisters of any size or material, including flexible formats or pallet wrappings or straps for stabilisation and protection of products put on pallets during transport, shall ensure that at least 40 % of such packaging in total is reusable packaging within a re-use system.’ (2) From 1 January 2030, by way of derogation from paragraph 1 of this Article, economic operators that use transport packaging or sales packaging used for transporting products, in the forms as listed in paragraph 1 of this Article, within the territory of the Union, between different sites on which the operator performs its activity, or between any of the sites on which the operator performs its activity and the sites of any other linked enterprise or partner enterprise, as defined in Article 3 of the Annex to Recommendation 2003/361/EC as applicable on 11 February 2025, shall ensure that such packaging is reusable within a re-use system’. (3) From 1 January 2030, by way of derogation from paragraph 1, economic operators that use transport packaging or sales packaging used for transporting products, including for products distributed via e-commerce, in the forms as listed in paragraph 1, to deliver products to another economic operator within the same Member State shall ensure that such packaging is reusable within a re-use system.’ Commission’s interpretation: The re-use targets for transport packaging (and sales packaging used for transporting products) are limited to situations where such packaging is used ‘within the territory of the Union’. Thus, both operators, i.e importers and distributors, must be located in the EU. In relation to transport packaging (and sales packaging used for transporting products) from third countries, this requirement should be understood as applying from the moment of import, and placing on the market, which means that it has completed all required import procedures and is allowed to circulate on the EU market. This typically takes place in the first warehouse in the EU. The re-use targets shall apply to imported goods in transport packaging after they are placed on the EU market. These targets shall apply from the first warehouse located within the Union until the final destination within the Union territory, where the first warehouse is not the final destination of the consignment. For the purpose of this provision, the ‘first warehouse’ means the facility within the Union where goods in transport packaging first arrive and are stored and unpacked for the purpose of onward distribution within the EU supply chain. Consignments arriving at the first warehouse and destined for a single final destination shall not be required to be unpacked and repacked into reusable packaging. Distribution centres and logistics hubs shall not be considered as final destination.

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Source: EUR-Lex (Cellar) · retrieved 2026-09-07