Commission adopts first Delegated Act

On 25 February 2026, the European Commission adopted its first Delegated Act under the Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40.

This exempts pallet wrapping films and strapping used to secure goods during transport from the 100% reuse obligation set out in Article 29(2) and 29(3) for intra-company and intra-group transport within the Union, as well as for transport between companies within the same Member State.

The Decision is based on the 15 December 25 Commission’s feasibility assessment and will enter into force on the 20^th day following its publication in the Official Journal of the European Union (OJEU), provided that neither the European Parliament nor the Council objects within the objection period ending by 25 April 2026.

Under the PPWR, economic operators using transport packaging or sales packaging used for transporting products, including pallet wrapping films and strapping, are in principle required to ensure the packaging is fully reusable within a reuse system.

The Commission’s feasibility assessment concluded that reuse systems for flexible load-securing materials are not yet sufficiently scalable or economically viable, and that mandating full reuse would require significant investments in still underdeveloped automated reuse solutions, imposing disproportionate costs and operational burdens for economic operators, with limited additional environmental benefit.

Despite this exemption, pallet wrapping films and strapping remain subject to the broader PPWR reuse framework, and economic operators must still comply with the overall target, ensuring at least 40% of transport and sales packaging is reusable by 1 January 30.

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