PPWR in force: what Regulation (EU) 2025/40 means for strap and closure buyers

On 22 January 2025 the EU published Regulation (EU) 2025/40 on packaging and packaging waste in its Official Journal. It entered into force on 11 February 2025 and is due to apply generally from 12 August 2026, as Osborne Clarke’s summary of 25 February 2025 sets out, and its full title confirms that it repeals Directive 94/62/EC. Because it is a regulation rather than a directive, the same text will apply directly in every member state.

The regulation reaches well beyond consumer packaging, and strapping buyers have a concrete reason to read it: the regulation text mentions straps by name. This guide explains where, which dates matter for strap and closure purchasing, and what is worth recording in 2025 while the detailed implementing rules are still to be written.

Where straps appear in the regulation

Article 3 defines transport packaging as packaging conceived to facilitate the handling and transport of one or more sales units, excluding road, rail, ship and air containers. A strap holding cartons on a pallet fits that description comfortably.

The explicit mention comes in Article 29, the re-use targets. From 1 January 2030, economic operators using transport packaging in the listed formats within the EU must ensure that at least 40% of it is reusable within a re-use system, and they must endeavour to reach 70% from 1 January 2040. The formats include pallets, boxes, crates, drums and similar items, and the article expressly adds flexible formats, pallet wrappings or straps used to stabilise and protect products on pallets during transport.

Two further paragraphs, drafted as derogations, are stricter still. Packaging moved between an operator’s own sites, or to linked and partner enterprises, must be reusable within a re-use system, and so must packaging used to deliver products to another operator in the same member state. Article 29 also sets out exclusions: transport of dangerous goods, custom-designed packaging for large-scale machinery and equipment, flexible transport packaging in direct contact with food and feed, and cardboard boxes.

How these rules will treat a single-use strap on a reusable pallet is not answered by the article alone. That belongs with legal advisers and future Commission guidance, not with assumptions.

The dates strapping buyers should note

Date in the text	Provision	Relevance to strap and closures
11 February 2025	Entry into force	The legal text is fixed; implementing and delegated acts follow
12 August 2026	General application	Conformity and documentation duties begin for packaging placed on the EU market
12 August 2028, or later	Harmonised material-composition labels (Article 12)	Labelling of packaging, separate from logistics labels on cartons
1 January 2030, or later	Recyclability performance grades A to C (Article 6)	Applies to all packaging placed on the market
1 January 2030, or later	35% minimum recycled content for other plastic packaging (Article 7)	Relevant to PET and other plastic strap
1 January 2030	Re-use targets for transport packaging (Article 29)	Straps are named among the formats
1 January 2030, or later	Maximum 50% empty space ratio for transport packaging (Article 24)	A unit-load design question rather than a strap choice

“Or later” follows the regulation’s own wording. Several obligations start on a fixed date or a set period after the Commission adopts the relevant implementing or delegated act, whichever comes later.

Plastic strap and the recycled-content question

Article 7 sets minimum recycled content for plastic packaging, calculated as an average per manufacturing plant and year. For plastic packaging outside the contact-sensitive and beverage-bottle categories, the figure is 35% from 2030, rising to 65% from 1 January 2040. Eligible recycled content must come from post-consumer plastic waste.

Two details deserve attention from PET strap buyers. First, the obligation is measured as a plant average, so a strap maker’s declaration should explain how the figure is calculated and verified rather than simply print a percentage. Second, Article 7 exempts any plastic part representing less than 5% of the total weight of the whole packaging unit. Whether a strap on a loaded pallet benefits from that exemption depends on how the packaging unit is defined, which the methodology work still has to settle. Record the question instead of relying on the answer you would prefer.

Woven polyester strap raises the same points. A supplier who states recycled content should be able to say whether the material is post-consumer and on what basis the statement is made.

Metal closures and mixed-material systems

Wire buckles, sheet metal clips and steel seals are steel components joined to plastic or steel strap. Article 6 links recyclability to design-for-recycling criteria and performance grades that the Commission will set through delegated acts. Until those criteria exist, nobody can grade a particular strap-and-closure combination with authority.

What a buyer can do is make the system easy to describe: strap material and construction, closure material and finish, and how the joint is cut and separated at the receiving end. That description will be needed however the criteria are finally written.

Practical steps for 2025

• List your transport packaging formats. Include strap type, width and closure for each packing line and route.
• Map flows that stay inside one company or one member state. These face the stricter Article 29 derogations from 1 January 2030.
• Ask strap suppliers how recycled content is stated. Request the basis, the material source and the verification method.
• Keep closure details with the strap specification. Material, finish and joint method belong in the same record.
• Track implementing and delegated acts. Several start dates depend on them.

None of this requires changing a working packing line in February 2025. It does mean that the evidence requested from August 2026 onwards, and again in 2030, will be easier to supply if the records exist.

Bringing it back to the specification

When a strap or closure review begins, keep the existing system identifiable. YAKU’s PET strap, woven strap and sheet metal clip pages show the variables worth recording, and the enquiry page is the place to describe the application. Material declarations and performance data are discussed per enquiry and remain on request.