Pallets, Stretch Film, Strapping: What the PPWR Expects From Importers

Pallets, Stretch Film, Strapping: What the PPWR Expects When Your Goods Arrive From Outside the EU

The truck from the port backs up to your dock. The goods were made in Izmir, or Shenzhen, or Cleveland; the invoice names a manufacturer three time zones away. Around the goods sits a wooden pallet, a few hundred grams of stretch film and two polyester straps — and under Regulation (EU) 2025/40, every one of those items is packaging placed on the EU market. The regulation does not ask where the manufacturer sits. It asks who placed the packaging on the market here — and when the manufacturer is outside the Union, that answer is usually you.

This concerns more roles than the word "importer" suggests. A brand that has its products made in a third country and ships them in is an importer in the regulation's sense. A distributor bringing in a foreign catalogue is one. And converters supplying film or strapping to either of them are being asked for evidence about items their customers long treated as freight accessories rather than packaging. This article maps what actually applies to the transport level — what is already in force, what waits until 2030, and the one carve-out that film and strapping received in February 2026.

Three Levels, and Each One Is Packaging

The PPWR defines three levels of packaging in Article 3, and recital 10 maps them onto the vocabulary most warehouses already use: sales packaging corresponds to primary packaging, grouped packaging to secondary packaging, and transport packaging to tertiary packaging. The box the end customer opens is sales packaging (Article 3(1)(5)). The tray or wrap that bundles sales units together is grouped packaging (Article 3(1)(6)). And the packaging conceived to facilitate handling and transport of several sales units or grouped packagings, so that they arrive undamaged, is transport packaging (Article 3(1)(7)).

The point that changes budgets: each level placed on the market is a packaging unit in its own right. A pallet is packaging. The stretch film around it is packaging. The straps stabilising the load are packaging — Article 29(1) names them expressly, listing pallets and then "flexible formats or pallet wrappings or straps for stabilisation and protection of products put on pallets during transport". One shipped product can therefore carry three packaging units, each with its own assessment and its own paper trail. The only transport equipment excluded from the definition is the road, rail, ship and air container itself: the sea container is not packaging, but everything on the pallet inside it can be.

Two edge cases worth pinning down early. E-commerce packaging is defined as transport packaging used to deliver products in the context of distance sales to the end user (Article 3(1)(8)) — so the shipping box of a parcel is regulated at the transport level even though a consumer touches it. And the same physical object can sit at different levels in different flows: a crate that reaches the end customer as part of the sales unit is not playing the same role as a crate that only moves stock between warehouses. The classification follows the function in the flow, which is why it has to be recorded per product and per channel rather than assumed from the object.

The Manufacturer Is Outside the EU. The Obligations Are Not.

The PPWR attaches most duties to placing on the market — the first time packaging is made available in the Union. A manufacturer in a third country never does that; the operator who imports the packaged goods does. That is the legal hinge on which the whole import scenario turns, and it works the same whether you are a trading company, a retailer sourcing own-brand production abroad, or a brand owner with contract manufacturing outside the Union.

For extended producer responsibility, Article 3(1)(15) defines the "producer" — the operator who owes registration and fees — and an importer making packaged products available for the first time in a Member State fits it squarely. Since 12 August 2026, that producer must be registered in each Member State where it first makes packaging available (Article 44): EPR under the PPWR is national, country by country, not a single EU filing. Selling into six markets means six registrations, six reporting lines and six fee schedules. Operators established in one country — or outside the Union — and selling directly to end users in another Member State must in addition appoint an authorised representative for EPR in that market, one per Member State (Articles 3(1)(15)(c) and (d), 3(1)(20) and 45(3)). Producers below 10 tonnes of packaging per year in a Member State can use simplified reporting there, and the annual report is due by 1 June.

Now connect this to the previous section: the declared volumes include the transport level. The pallet, film and strapping arriving around your goods are packaging you place on the market, and they belong in your EPR declarations alongside the boxes and bottles. Operators who have only ever counted their sales packaging are usually under-declaring — not by a rounding error, since a loaded pallet often weighs more than all the sales packaging stacked on it.

What Applies Now

Since 12 August 2026, the general obligations of the regulation apply to transport packaging exactly as they do to a retail box.

Substances. Article 5 restricts lead, cadmium, mercury and hexavalent chromium in any packaging — pallets and films included.

Recyclability assessment. Article 6 requires each packaging unit to be assessed for design for recycling and graded A, B or C. The assessment duty runs now; the market gate arrives later — from 1 January 2030, packaging below grade C cannot be placed on the market. A stretch film is assessed like any other plastic packaging.

The declaration and the file. Article 39 requires an EU Declaration of Conformity per packaging type, backed by the Annex VII technical documentation — kept for five years, ten for reusable packaging. When the manufacturer is outside the Union, assembling that file is exactly the evidence problem importers now face: the substance declarations and recycled-content data sit with suppliers who have never been asked for them.

Perceived volume. Article 10(2) already prohibits packaging whose characteristics aim only to increase the perceived volume of the product — double walls, false bottoms, unnecessary layers. For e-commerce flows, where the shipping box is transport packaging by definition, this is in force today, not in 2030.

What Waits Until 2030

The empty-space ratio. Article 24 caps empty space at 50% — but for grouped, transport and e-commerce packaging only; sales packaging has no ratio and answers to the Article 10 minimisation rules instead. The cap applies from 1 January 2030 or 36 months after the implementing act under Article 24(2) enters into force, whichever is later — and that act has not been adopted yet. So the air in your parcels is not an infringement today; it is a 2030 problem you should start measuring now, because the fix is usually a packaging redesign with a long lead time.

The re-use targets. From 1 January 2030, Article 29 sets re-use targets: 40% of transport packaging used, and 10% of grouped packaging. The 2040 figures — 70% and 25% — are phrased as "shall endeavour", an obligation of effort rather than result. Read the scope carefully: the targets bind the economic operators that use transport packaging within the territory of the Union. An arriving flow from a third country is not in scope as such — the operator using that packaging within the Union is. What happens to a pallet between Shanghai and Rotterdam is not what the targets measure; what your warehouses do with pallets circulating inside the Union is.

The exemptions are just as load-bearing as the targets. Article 29(4) takes out of scope, among others, packaging for dangerous goods, custom packaging for large machinery, flexible formats in direct contact with food — and cardboard boxes. Article 29(13) exempts micro-enterprises placing no more than 1,000 kg of packaging per year in a Member State. And the practical route to the transport target is one most operators already know: pallets head the Article 29(1) list of formats, and pooled or rented pallets circulating between operators are the established way re-use already runs at scale. If your inbound flows ride on pool pallets, part of the 2030 conversation is already solved; the film and strapping around them is where the questions concentrate.

The Film and Strapping Carve-Out: C(2026) 511

On 25 February 2026, the Commission adopted delegated decision C(2026) 511, exempting pallet wrapping films and straps from the 100% re-use targets of Articles 29(2) and 29(3). That is a real relief for single-use film in the flows those paragraphs cover — and it is also exactly as narrow as it sounds. The decision does not remove film or strapping from the definition of packaging: they are still assessed, still declared, still counted in EPR volumes, and still inside the empty-space scope from 2030. A carve-out from one article's targets is not an exit from the regulation — treating it as one is how a compliant warehouse acquires a non-compliant loading dock.

One Shipment, Three Declarations: Holding the Evidence Together

The pattern that keeps this manageable is the one the regulation itself suggests: record each packaging level as its own unit, and let the evidence attach to the level it belongs to. The pallet carries its material and weight data, the film carries its substance declaration, the sales box carries its recyclability grade — and the Declaration of Conformity for each type stands on its own file. Operators who fold the transport level into a "logistics" line outside the packaging inventory rediscover it in 2030 with no data behind it.

This is exactly how PPWR Connect models it: each SKU line carries a packaging level — sales, grouped or transport — so a pallet or a stretch film is inventoried, assessed and documented like any other unit, and the EPR volumes roll up with the transport level included. You can see a complete worked example in the live demo, including a transport-level unit with its evidence attached. And if you import and are not sure which of these obligations reach you first, start with the free PPWR readiness assessment — it maps your role and your flows to the obligations, transport level included. For the wider import picture beyond packaging levels, our importer and distributor checklist covers registrations, timing and documents step by step.