Pallets, wooden crates, stretch film, straps, plastic containers, bulk cartons, drums, IBCs — transport packaging is the category most companies think about least and get wrong most often. It never reaches a consumer, it rarely carries a brand, and it is frequently assembled from components made by three or four different suppliers. Under Regulation (EU) 2025/40 (PPWR), it is also the category where the manufacturer role under Article 15 and the Producer role under Articles 44 and 45 are most likely to sit with different companies than intuition suggests — and, in one important scenario clarified during 2026, with the packaging maker rather than the packaging user.
This article explains what transport packaging covers, the structural rule that makes it behave differently from sales packaging, the "final form" test the Commission uses to identify its manufacturer, the genuinely unresolved divergence between the Commission and national registers on this point, and the specific complication of packaging of packaging — the pallets and film used to ship empty packaging to whoever will fill it.
What Counts as Transport Packaging
PPWR replaced the old primary/secondary/tertiary vocabulary with sales, grouped and transport packaging, defined in Article 3(1). Transport packaging covers what moves goods between businesses and through logistics chains: pallets, boxes, trays, plastic crates, intermediate bulk containers, pails, drums and canisters of any size or material, including flexible formats and the pallet wrappings and straps used to stabilise and protect products on pallets during transport (European Parliament & Council of the European Union, 2025).
E-commerce packaging — parcel boxes, mailing bags, protective fill — is a defined subset of transport packaging carrying some obligations of its own, notably under the empty-space rules. Material is irrelevant to classification: a wooden pallet, a steel drum and a polyethylene stretch film are all transport packaging, and all sit inside the same framework.
The Rule That Changes Everything: Transport Packaging Is Placed on the Market Empty
This is the single structural point that makes transport packaging behave differently from everything else, and it is where most incorrect analysis begins.
Sales and grouped packaging are generally placed on the market when they are filled. Transport and service packaging are generally placed on the market empty (European Commission, 2026b). The empty box, the empty pallet, the roll of stretch film — these are placed on the market as products in their own right, by whoever supplies them, before any goods are ever put inside or around them.
The consequence follows directly. If placing on the market happens at the empty stage, then the operator that first makes that empty packaging available in a Member State is the one the Producer analysis points at — not, as many companies assume, the operator that later fills a box or wraps a pallet. The Commission has stated that PPWR seeks to define one producer per packaging, whether that packaging is empty — as with transport and service packaging — or made available containing products, as with sales and grouped packaging (European Commission, 2026a).
For packaging manufacturers, this is the uncomfortable part: a company that has always understood itself as "just the box maker," responsible at most for conformity, may now find the Producer registration and EPR financing obligation pointing back at it.
Who Is the Manufacturer? The "Final Form" Test
Transport packaging is often assembled from several components — a pallet from one supplier, wrap from another, straps from a third. So at which point in that assembly is the manufacturer identified?
The Commission's answer is the final form test: the manufacturer of transport packaging is identified at the stage where the empty packaging has reached its final form, meaning it can be used without any further components being added (European Commission, 2026b). Each component that reaches its own final form and is placed on the market as packaging is assessed on its own terms.
Two applications of this matter in practice:
Unbranded generic transport packaging. Where unbranded, standardised cardboard boxes are manufactured and sold within the same Member State, the party that manufactures them will usually qualify as the producer — rather than the party that later fills the box and closes it with adhesive film (European Commission, 2026b). The same logic reaches flexible formats: for unbranded stretch film and pallet wrap, the Commission identifies the manufacturer as the company that physically manufactures the wrap and places it on the market as packaging, not the company that buys the wrap and uses it to secure goods.
Branded packaging. Applying your own name or trademark to packaging can make you the manufacturer under PPWR, with the corresponding conformity responsibilities, even where a third party designed, produced or filled it. For unbranded packaging, the decisive question is not who owns the factory but who designed and specified the packaging. This is also why contract-manufacturing arrangements need separate assessment: the company ordering the packaging can qualify as the manufacturer depending on how the arrangement is structured.
A Practitioner's Note: This Point Is Not Settled
Here honesty serves compliance better than confidence. The Commission's position above comes from guidance and FAQs, which are interpretive instruments — they do not amend the Regulation, and they do not bind national authorities in the way the Regulation itself does.
The European National Registers for Packaging Network — national authorities and producer registers from sixteen countries — had previously agreed on a different approach to identifying the manufacturer of transport packaging. Germany's ZSVR, for example, had guidance pointing toward the filler rather than the box maker in e-commerce contexts. Whether national registers will now align with the Commission's interpretation remains genuinely open.
The practical implication is not paralysis; it is documentation. A company relying on the Commission's final-form reasoning to conclude that it is not the Producer of a given transport-packaging stream should record that reasoning, and should check the destination Member State's register guidance rather than assuming the Commission's position has already been adopted there.
Packaging of Packaging: When the Cargo Is Itself Empty Packaging
Now the case that trips up packaging suppliers specifically. A carton manufacturer sells 20,000 empty boxes to a filler. Those boxes travel stacked on pallets, wrapped in stretch film, secured with straps.
There are two distinct packaging populations in that single truckload, and they must be analysed separately:
- The empty cartons — the cargo. These are the product being supplied. Under the empty-placement rule, the carton manufacturer places them on the market when it supplies them.
- The pallets, film and straps — transport packaging in their own right, used to move the cargo. The filler receives them, unwraps them, and discards or returns them. For that stream, the filler is very often the end user, and the carton manufacturer is the operator that made that transport packaging available.
A supplier that has correctly worked out its position on the cartons has not thereby worked out its position on the pallets and film — those are a separate stream, with a separate Producer analysis, and potentially separate reporting. This is the "packaging of packaging" problem in its simplest form, and it multiplies through any supply chain where packaging components move between converters, printers, fillers and distributors before anything is ever sold to a customer.
Where Article 15/17 and Articles 44–45 Diverge
Because these two tracks are frequently conflated, it is worth setting them side by side.
| Conformity track | EPR track | |
|---|---|---|
| Who | Manufacturer (Art. 3(1)(13)) | Producer (Art. 3(1)(15)) |
| Core duty | Draw up the EU declaration of conformity; hold technical documentation; ensure only compliant packaging is placed on the market (Art. 15) | Register in the national producer register; report; finance packaging-waste management (Arts. 44, 45) |
| Geographic unit | One manufacturer Union-wide for a given packaging item | One producer per Member State |
| Representation | Manufacturer's Authorised Representative under Art. 17, appointed by written mandate for specified tasks | EPR Authorised Representative under Art. 45, established in the specific Member State |
For transport packaging, the same company frequently ends up on both tracks — as manufacturer of the empty format it produces, and as Producer of that same format in the Member State where it first makes it available. That is not double-counting; they are two different obligations with different administrative homes. Equally, they can split: an operator may be the manufacturer of a packaging item Union-wide while a different operator is the Producer of it in a given Member State.
The representation consequence matters for non-EU suppliers. A manufacturer established outside the EU may appoint an Article 17 authorised representative for specified conformity tasks — but core duties, such as ensuring only compliant packaging is placed on the market, cannot be delegated through that mandate. And an Article 17 mandate does nothing for the Article 45 EPR side, which requires its own appointment, in the specific Member State concerned.
Reuse Targets: Article 29 and the Pallet Wrap Exemption
From 1 January 2030, economic operators must ensure that at least 40% of the transport packaging they use — pallets, boxes, trays, plastic crates, IBCs, pails, drums and canisters of any size or material, including pallet wrappings and straps — is reusable within a re-use system. The corresponding 2040 figure of 70% is an endeavour obligation, not a binding target (European Parliament & Council of the European Union, 2025).
Two refinements matter:
- Commission Delegated Decision (EU) 2026/429 exempts economic operators using pallet wrappings and straps from the 100% reuse requirements under Article 29(2) and (3). For the uses covered by the exemption, the Article 29(1) quotas do not apply; pallet wrappings and straps used in other Article 29(1) transport operations remain inside the overall 40% calculation.
- Custom-designed transport packaging — specialised pallets and crates engineered for a specific product or supply chain — is treated differently from standardised pooled formats, on the basis that it is not suited to standardised reuse models.
Responsibility for reuse targets does not follow the Producer analysis. It attaches to the user of the transport packaging — which may be a manufacturer, importer or distributor depending on the operation. For transport packaging imported from third countries, the targets apply from the moment of import, with the relevant procedures typically taking place at the first EU warehouse the packaging reaches.
Empty Space: Article 24
From 1 January 2030 — or three years after the Commission adopts the calculation methodology, due by 12 February 2028, whichever is later — the empty-space ratio in grouped, transport and e-commerce packaging must not exceed 50%. Void fill counts as empty space: bubble wrap, air cushions, polystyrene chips and paper cuttings all count toward the ratio rather than against it. A separate and earlier duty applies to sales packaging from 12 February 2028, requiring empty space to be reduced to the minimum necessary.
What to Do With This
- Inventory transport packaging as its own population. Separate from sales and grouped packaging, and separated again by component — pallets, cartons, film and straps are distinct streams that can each reach final form independently.
- Apply the empty-placement rule deliberately. For each transport-packaging stream, identify who first makes the empty format available in each Member State, rather than defaulting to whoever fills or wraps.
- Check branding on every format. An unbranded generic format and the same format carrying your logo can produce different manufacturer conclusions.
- Do not treat the Commission FAQ as the final word. Where your conclusion depends on the final-form interpretation, verify the destination country's register guidance and keep your reasoning documented.
- Track the reuse and empty-space clocks separately from EPR. They attach to different operators, on different dates, and being registered as a Producer says nothing about whether you have met Article 29 or Article 24.
Frequently Asked Questions
Is a wooden pallet packaging under PPWR? Yes. Pallets are expressly within the transport-packaging formats named in the reuse provisions, regardless of material.
Who is the producer of an unbranded cardboard box — the box maker or the company that fills it? The Commission's position is that where unbranded standardised boxes are manufactured and sold within the same Member State, the manufacturer usually qualifies as the producer. Note that national registers have previously taken a different view, so verify the destination country's guidance.
Is stretch film packaging? Yes. Pallet wrappings and straps are named transport-packaging formats. For unbranded wrap, the Commission identifies the film manufacturer, not the user, as the manufacturer.
Are pallet wrappings exempt from reuse requirements? Delegated Decision (EU) 2026/429 exempts covered operators from the 100% requirements in Article 29(2) and (3). It does not remove pallet wrappings and straps from the overall 40% calculation in other Article 29(1) operations.
If I appoint an Article 17 authorised representative, does that cover my EPR obligations for transport packaging? No. Article 17 covers specified conformity tasks for the manufacturer. EPR representation under Article 45 is a separate appointment, made per Member State.
Transport packaging is where the manufacturer and Producer roles most often separate — and where the same company most often holds both without realising it. Beyoğlu Professional maps each packaging stream to the right role, register and Member State. Check your EU scope to see where your transport-packaging obligations actually sit.
References
European Parliament & Council of the European Union. (2025). Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, amending Regulation (EU) 2019/1020 and Directive (EU) 2019/904, and repealing Directive 94/62/EC. Retrieved from EUR-Lex.
European Commission. (2026a). Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste. Retrieved from EUR-Lex.
European Commission. (2026b). Frequently asked questions on the Packaging and Packaging Waste Regulation (PPWR) (updated 3 August 2026). Retrieved from the European Commission environment portal.
European Commission. (2026c). Commission Delegated Decision (EU) 2026/429 exempting economic operators using pallet wrappings and straps from the 100% reuse requirement. Retrieved from EUR-Lex.
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