The PPWR pallet wrappings exemption, formally Commission Delegated Decision (EU) 2026/429, removes pallet wrappings and straps from the 100% reuse requirement in Article 29(2) and (3) of the EU Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40. Adopted on 25 February 2026 and in force since 26 May 2026, it is the first delegated act issued under the PPWR. For manufacturers and logistics operators, the takeaway is narrow but consequential. The 100% reuse tier no longer applies to these two formats, but the general 40% reuse target under Article 29(1) still applies from 1 January 2030. This guide explains what changed, what did not, and how to scope Article 29 accurately.

If your team is scoping EU packaging obligations now, you can request a compliance review to confirm how the reuse targets map to your transport packaging portfolio.

Key Takeaways

📌 Decision (EU) 2026/429 exempts pallet wrappings and straps from the 100% reuse tier in Article 29(2) and (3) of the PPWR.

⏳ The exemption entered into force on 26 May 2026. The underlying Article 29 reuse targets apply from 1 January 2030.

⚠️ The 40% general reuse target under Article 29(1) still applies to pallet wrappings and straps. Do not scope them out of it.

📄 A corrigendum adopted on 1 April 2026 removed recital language that had implied the 40% target also did not apply, resolving earlier ambiguity.

🏭 Affected operators include manufacturers, logistics providers, and any business using pallet wrappings or straps for intra-company, intra-group, or same-Member-State transport.

🔗 The exemption is unconditional within scope. No closed-loop, tracking, or geographic test applies beyond matching the Article 29(2) or (3) transport scenario.

🤖 CORA-powered regulatory intelligence tracks delegated acts and corrigenda like this one so reuse-target scoping stays accurate through the 2030 phase-in.

What the PPWR Pallet Wrappings Exemption Actually Changes

Before this Decision, Article 29 of the PPWR treated pallet wrappings (stretch films used to stabilise palletised loads) and straps as transport packaging subject to reuse obligations. In two defined scenarios, those obligations reached 100%. The Commission concluded, after a feasibility study and stakeholder consultation, that mandating full reuse of these single-use stabilisation formats would create disproportionate adaptation costs without a matching environmental benefit.

Decision (EU) 2026/429 resolves that by exempting these two formats from the 100% tier only. It does not weaken the PPWR's broader reuse ambition, and it does not exempt any other transport packaging format. You can confirm the operative text at EUR-Lex, and the general packaging rules on Certivo's PPWR framework page.

Article 29 Reuse Targets: The Layered Structure to Scope

The most common scoping error is treating Article 29 as a single flat "100% reuse" rule. It is not. Article 29 is layered, and the exemption touches only part of it.

The practical read

The exemption removes pallet wrappings and straps from the two 100% scenarios in 29(2) and 29(3). Everything else in Article 29 continues to apply. For a compliance team, this means the reuse-target model in your scoping documentation must reflect the 40%/100% split, not a single threshold. Teams managing packaging alongside chemical and environmental rules often centralise this in a single materials and environmental compliance view rather than separate spreadsheets.

Article 29 reuse target structure showing PPWR pallet wrappings exemption

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Why the 40% Target Still Applies, and the Corrigendum That Confirmed It

This is where market coverage diverged, so it deserves precision. The version of the Decision adopted on 25 February 2026 included a recital sentence stating that exempting these formats from Article 29(2)/(3) also meant the reuse quotas of Article 29(1) did not apply to them. That reading would have removed pallet wrappings and straps from the 40% target too.

On 1 April 2026, the Commission adopted a corrigendum that deleted that sentence from Recital 2. The Official Journal version published on 6 May 2026 does not contain it. As a result, the 40% general reuse target continues to apply to pallet wrappings and straps like other transport packaging formats. The corrigendum is available from the Council of the EU, and the European Commission's packaging waste page reflects the settled position.

Why this matters for scoping

If your team read the February or March 2026 coverage and concluded these formats were fully out of Article 29, that conclusion is now outdated. This is a textbook case for regulatory intelligence and horizon scanning: a delegated act, a corrigendum weeks later, and a materially different obligation depending on which version you scoped against.

Is the Exemption Conditional? What "Unconditional Within Scope" Means

Within its defined scope, the exemption carries no additional compliance test. There is no requirement to keep packaging inside a single Member State, no tracking or return-proof obligation, and no separate closed-loop condition beyond the transport scenarios already set out in Article 29(2) and (3).

There is one functional qualifier worth noting. The exemption covers pallet wrappings and straps used "for stabilisation and protection of products put on pallets during transport." That is a definition of the covered use, not an added hurdle. If the transport scenario matches 29(2) or 29(3), the exemption applies to the 100% tier. Legal basis for the empowerment is Article 29(18)(a) of the PPWR, confirmed in Regulation (EU) 2025/40.

Who Is Affected: Industries and Transport Scenarios

The exemption is horizontal. It applies wherever pallet wrappings or straps are used in the qualifying transport scenarios, regardless of sector.

🏭 Manufacturers shipping palletised goods intra-company, intra-group, or nationally within a Member State.

🔗 Logistics and distribution providers moving goods between linked or partner enterprises across the EU.

📊 Compliance and packaging teams scoping Article 29 obligations ahead of the 2030 phase-in.

Consumer goods, electronics, industrial equipment, and consumer goods manufacturers with high pallet throughput see the most direct operational relief, because they can continue using recyclable single-use stretch film for these two formats while still meeting the 40% reuse target across their wider transport packaging mix. For teams also tracking the Extended Producer Responsibility and Digital Product Passport workstreams, this Decision is one input among several converging EU packaging and product rules.

Key Dates and Enforcement Timeline

Enforcement of Article 29 sits with national competent authorities through market surveillance once the reuse targets apply from 2030. The exemption itself is effective now, so scoping decisions taken today should already exclude pallet wrappings and straps from the 100% tier while retaining them in the 40% calculation.

PPWR pallet wrappings exemption timeline from adoption to 2030 reuse targets

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Compliance Risks and Audit Readiness Under Article 29

The risk here is not a new obligation. It is mis-scoping an existing one. Two failure modes stand out.

First, over-exemption. Teams that read pallet wrappings and straps as fully out of Article 29 will understate their 40% reuse target base and risk a shortfall when the target applies in 2030.

Second, version drift. Because a corrigendum changed the substance weeks after adoption, any scoping decision based on the first published narrative may be wrong. This is a data versioning problem as much as a legal one.

Audit types this affects

• Internal audits: confirming the reuse-target base is calculated on the corrected Article 29 structure.

• Customer audits: retailers and OEMs increasingly request packaging compliance evidence as part of supplier reviews.

• Regulatory market surveillance: national authorities may request evidence of reuse-target scoping from 2030.

Sound practice is point-in-time evidence: a time-stamped record of which regulatory version informed a scoping decision, who approved it, and when. That is the difference between being audit-ready and being caught by version drift. No system makes an organisation audit-proof, but continuous audit-ready documentation reduces surprises and shortens response time when an auditor asks how you scoped Article 29.

How to Scope Article 29 Obligations: A Practical Checklist

✅ Reclassify the two formats. Flag pallet wrappings and straps used in Article 29(2)/(3) scenarios as exempt from the 100% tier, effective 26 May 2026.

✅ Keep them in the 40% base. Continue counting these formats toward the Article 29(1) 40% target from 1 January 2030.

✅ Do not add a closed-loop test. Confirm only that the transport scenario matches 29(2) or 29(3). No further condition exists.

✅ Update scoping documentation. Replace any single flat "100%" model with the layered 40%/100% structure.

✅ Re-check version basis. Confirm your scoping reflects the corrected text, not the pre-corrigendum recital.

✅ Map to your transport packaging mix. Identify which other formats drive your 40% target so exemptions are applied correctly.

📄 Retain evidence. Keep time-stamped records of the regulatory version and approval behind each scoping decision.

For teams replacing spreadsheets, a BOM and packaging-level compliance view keeps these classifications consistent across sites and product lines.

How AI-Native Compliance Automation Keeps Scoping Accurate

This Decision is a small change with an outsized lesson. A delegated act, a corrigendum, and a phased applicability date together determine whether two packaging formats sit in a 40% base, a 100% tier, or neither. Getting it right by hand, across every site and product line, is where manual processes fail.

CORA-powered regulatory intelligence monitors delegated acts and corrigenda under frameworks like the PPWR and flags exactly this kind of mid-cycle change, so scoping does not drift from the current legal text. CORA-enabled analysis maps reuse-target logic to your transport packaging formats, and a centralized compliance data backbone holds the time-stamped evidence behind each decision. The result is a shift from reactive checks to continuous compliance monitoring as EU packaging rules keep evolving.

Manufacturers using Certivo for multi-jurisdiction packaging, chemical, and ESG obligations manage these workstreams in one system rather than tracking each delegated act separately. That matters when the next PPWR delegated act lands, and more are expected as Article 29 and related provisions mature toward 2030.

Executive Conclusion

The PPWR pallet wrappings exemption is deliberately narrow. Decision (EU) 2026/429 lifts the 100% reuse requirement from pallet wrappings and straps in the Article 29(2) and (3) transport scenarios, and nothing more. The 40% general reuse target under Article 29(1) still applies to these formats from 1 January 2030, confirmed by the corrigendum that removed the conflicting recital. For compliance leaders, the action is to scope Article 29 on its layered structure, exclude these two formats from the 100% tier, retain them in the 40% base, and keep evidence of which regulatory version informed the decision.

To confirm how the PPWR reuse targets map to your packaging portfolio, book a compliance risk assessment with a Certivo specialist.