BP Consultants conducted a study on reusable and reuse targets in the PPWR on behalf of BKV GmbH (the think tank of the German plastics industry). Against the backdrop of the use of reusable and single-use packaging, the study addresses both the regulatory framework and the current state of practice regarding the relevant plastic transport and sales packaging with a transport function. The study evaluates regulatory requirements, analyzes established reusable systems, identifies their technical and economic challenges and limitations, addresses issues of hygiene and food safety, and examines the topic of minimum circulation rates. Through six key questions for policymakers, the study concludes by outlining essential aspects for successful implementation and the achievement of reuse targets.
Starting Point
The new European Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) entered into force on February 11, 2025. A relevant part of the new regulation concerns reuse targets and possible exemptions.
BKV GmbH is the think tank of the German plastics industry. With the study developed by BP Consultants, it aims to ensure transparency. Against the backdrop of reusable and single-use applications, the study addresses both the regulatory framework and the current state of practice regarding the affected plastic transport packaging and plastic sales packaging with transport functions.
Packaging and Interviews
For the study, 11 interviews were conducted with packaging experts at European or global industrial companies, packaging manufacturers, and associations. The interviewees came from the fields of packaging development, procurement, logistics, and sustainability.
With regard to the packaging formats covered under Article 29(1) of the PPWR, the focus was on five categories: buckets, drums, canisters, intermediate bulk containers (IBCs), and flexible intermediate bulk containers (FIBCs).
Three Perspectives
Methodologically, BP Consultants examined three different perspectives as part of the study “Reusable Targets in the PPWR and Possible Exemptions from Reusable Obligations”:
- a regulatory assessment of the PPWR regarding the reusable rate in the area of transport packaging and sales packaging with a transport function,
- an analysis of established reusable systems in the area of transport packaging and sales packaging with a transport function,
- identification of challenges and limitations for reusable systems in the sector of plastic transport packaging and sales packaging with transport functions from a practical perspective through extensive expert interviews.
Conclusion and open questions
- The comprehensive results highlight the technical and economic challenges in the context of the reuse targets in Art. 29(1)-(3) PPWR for the packaging formats examined.
- The rationale for delegated acts regarding further exemptions under Article 29(18) of the PPWR lies particularly in issues of hygiene and food safety and the associated requirements.
- In addition, the study highlights the challenges regarding the establishment of minimum circulation rates for reusable packaging in light of Article 11(2) of the PPWR.
Six Key Questions for Policymakers
Based on the detailed results from the three perspectives, BP Consultants formulated six key questions directed at policymakers. From the authors’ perspective, answering these questions is essential for the successful implementation and achievement of reuse targets.
Question 1: Transport packaging and sales packaging with a transport function
Does direct contact really make a difference for reuse rates?
- The distinction between transport packaging and sales packaging with a transport function is neither understandable nor useful. A slim majority of survey participants classify the packaging systems under discussion primarily as sales packaging, since there is direct contact with the contents. Some participants would therefore like to see sales packaging excluded from the reusable packaging regulation.
- On the other hand, IBCs appear to meet the 40 percent reusable rate, even though they have direct product contact.
- Furthermore, reusable plastic crates for meat and fruit are also in direct contact with the product. However, due to product-specific standardized crates and a safe cleaning process, this does not result in any hygiene or quality issues.
Question 2: Minimum number of cycles for reusable packaging
Is it realistic to define this based on an ecological break-even value?
Article 11(2) of the PPWR stipulates a minimum number of circulation cycles for reusable packaging, which must still be determined by a delegated act for the most commonly used packaging formats in the reusable sector.
- An analysis of available studies on PPWR-relevant packaging systems has shown that even in cases where multiple studies (mostly life cycle assessments) exist for a reusable system, these studies reach different conclusions regarding the required minimum number of cycles for the ecological break-even point due to varying framework conditions and scenarios.
- Furthermore, the studies also differ on the question of how many cycles are considered realistic.
Against this background, establishing a minimum number of circulation cycles for reusable packaging based on an ecological break-even point appears to be extremely difficult from a methodological standpoint.
Question 3: Exceptions provided for by the PPWR
Well-known and useful, but sufficient and clear?
- The transport of hazardous goods is by far the most frequently cited exception to the reusable packaging requirements mentioned by survey participants. Although no direct question was asked on this topic, participants expressed a desire to also exclude hazardous substances as an exception. The risk of migration of non-removed, migrated substances from the packaging material into new products was cited as the reason.
- The rationale for delegated acts establishing further exemptions lies in the areas of hygiene and food safety, and examples demonstrate the necessity of such exemptions.
- However, defining critical use cases that could potentially be exempted is difficult (example: construction mortar in buckets might be acceptable for reuse, whereas construction paint might not be).
- There is considerable uncertainty regarding how the industry should handle exemptions (for example: What should be done if reusable packaging cannot be used for hygiene reasons?).
Question 4: Standards and Reusable Infrastructure
How can both be developed in a short time?
Successful reusable packaging systems are pooling systems that offer standardized, purpose-built solutions and provide a dedicated reusable infrastructure with options for reconditioning.
- The development of standards and reusable infrastructure is time-consuming and costly.
- The necessary standards and reusable infrastructure are virtually nonexistent in the EU today for buckets, canisters, and FIBCs, and exist only to a very limited extent for drums.
- Of the five packaging systems analyzed, it appears that only IBCs will be able to complete the necessary preparatory work by 2030.
Question 5: Types of pooling systems according to the PPWR
Closed Loop versus Open Loop?
Existing reusable systems (prior to February 2025) are partially grandfathered in. Nevertheless, they must continue to meet basic requirements such as reporting obligations.
- There is no uniform understanding of the terms “closed loop” and “open loop” in the market.
- Is a distinction actually necessary? Or could this be a part of the regulation where a simplified approach makes implementation more practical and feasible?
Question 6: PPWR Reusable Quotas
Is it really possible to assess whether the quotas are achievable or not?
- It is simply not possible to say whether an overall reusable quota of 40 percent is realistic, as there is no information available, neither in the PPWR explanatory memorandum nor in the technical literature or from experts, regarding the current overall share of reusable packaging in the relevant packaging mix (how large is the current gap?).
- Since the calculation method under Article 30(1) relies on a unit count to calculate the target under Article 29(1), but most companies do not have precise data on packaging in circulation, the survey participants had no idea whether an overall target of 40 percent under Article 29(1) is realistic.
- However, none of the respondents considers a 100 percent reusable rate, as required by Article 29(2) and Article 29(3), to be realistic.
- The current reuse rates for the five packaging systems analyzed vary widely, ranging from 0 percent to over 40 percent. Yet even these figures do not help in assessing whether an overall reuse rate of 40 percent is realistic or not.
Study Download
A free summary of the study’s contents is available here (PDF).
The full report can be ordered from BKV GmbH for a fee.
