Strapping reusable transport packaging: preparing for the PPWR re-use targets

Regulation (EU) 2025/40 entered into force on 11 February 2025 and is due to apply generally from 12 August 2026. For transport packaging, its most demanding provision comes afterwards: the Article 29 re-use targets, from 1 January 2030. Straps are named in that article. A buyer reading it in November 2025 has a little over four years to work out what a reusable flow means for the way loads are strapped.

What Article 29 requires

The regulation text sets three layers:

Flow	Requirement from 1 January 2030
Transport packaging in the listed formats used within the EU	At least 40% reusable within a re-use system; endeavour to reach 70% from 1 January 2040
Between an operator’s own sites, or to linked or partner enterprises	Reusable within a re-use system
Deliveries to another operator in the same member state	Reusable within a re-use system

The listed formats run from pallets, crates and drums to the pallet wrappings or straps used to stabilise products on pallets. Dangerous goods, custom-designed packaging for large-scale machinery, flexible packaging in direct contact with food or feed, and cardboard boxes sit outside all three layers. Article 29(13) also exempts micro-enterprises that make no more than 1,000 kg of packaging available in a member state in a calendar year, and Article 30 measures progress in equivalent units of the listed formats.

The regulation also brings documentation. As Osborne Clarke noted in February 2025, manufacturers must carry out a conformity assessment procedure. The regulation’s annex on that procedure requires the declaration of conformity to be kept with the technical documentation for five years after single-use packaging is placed on the market, and for ten years in the case of reusable packaging.

Where the strap sits in a reusable system

A reusable pallet or crate still needs its load stabilised on every trip. Broadly, there are three approaches:

Approach	Example	Questions to resolve
Single-use strap on a reusable carrier	PET strap with clips around cartons on a pooled pallet	How the strap is counted in the operator’s Article 29 calculation
Reusable securing device	Straps or bands with re-closable fastenings, designed for repeated cycles	Inspection, cleaning, return logistics and retirement criteria
Securing built into the carrier	Crates with lids, latches or interlocking stacking features	Whether the load still needs stabilising inside the unit

Neither Article 29 nor the equivalent-unit rule in Article 30 settles, on its own, how a single-use strap on a reusable pallet is treated in the 40% calculation. Take that question to legal advisers and watch for Commission guidance, rather than assuming an answer in either direction.

Designing closures for repeated cycles

If a strap or closure is meant to be used more than once, it becomes an item with a service life:

• Inspection. Define what makes a strap or closure unfit for further use: cuts, fraying, deformation, corrosion or a joint that will not hold tension.
• Finish. Galvanized and phosphated buckles are different finishes for different conditions. Frame the choice around the actual washing, storage and transport environment, and ask for evidence rather than assuming durability.
• Contact with the carrier. Strap edges and metal closures can wear moulded crates and pallets over many trips. Strap channels in the carrier keep the strap in position and protect both.
• Cycle records. A re-use system needs records. Decide whether straps and closures are tracked individually, by batch, or simply replaced at a fixed point in the loop.
• Return flow. Reusable straps need somewhere to go at the destination and someone responsible for sending them back.

Hygiene matters in food and pharmaceutical loops. A strap that touches cartons only may be treated differently from one that touches the product, and the carrier’s cleaning process may not suit every strap material.

Single-use strap is still a design decision

A loop that keeps single-use strap on reusable carriers still involves choices about that strap. A strap that is easy to cut without damaging the crate, a closure that separates cleanly at the destination, and a strap material that fits the destination’s waste collection all make a reusable loop cheaper to run. Record those properties in the specification, so that the strap can be reviewed when the rules on counting become clearer.

A procurement plan for 2026

1. Map transport flows by type: between own sites, within one member state and cross-border.
2. Mark which flows fall under the Article 29 exclusions.
3. For each remaining flow, record the carrier, strap, closure and the number of straps per unit.
4. Trial one reusable securing approach on a closed loop between two of your own sites.
5. Agree inspection and retirement criteria for any reusable strap or closure in writing.
6. Revisit the plan when the Commission issues guidance on Article 29.

Specify the closure as part of the loop

Whatever approach you choose, the strap and closure have to match. The woven strap, galvanized wire buckle, PET strap and sheet metal clip pages show the variables to record. Describe the loop, the carrier and the number of cycles you expect through the enquiry page; performance values are on request.