Does the PPWR also apply to transport packaging, pallets and shipping cartons?

Regulation (EU) 2025/40 (PPWR) clearly distinguishes between three packaging categories — and this distinction is decisive for your compliance effort.

Sales packaging (primary packaging that reaches the end consumer directly) is subject to the full set of obligations: material labelling, recyclability declaration, recycled content for plastics and digital product marking (QR code/GS1 Digital Link) — all applicable from the cut-off date of 12 August 2026.

Grouped packaging (secondary packaging such as cardboard around individual products) also falls under the PPWR when it is handed over to the end consumer together with the product. Labelling and minimisation obligations apply here as well.

Transport packaging (tertiary packaging such as pallets, stretch film and bulk cartons used exclusively for transport between businesses) is generally exempt from the labelling obligations under Article 11 — provided it never reaches the end consumer. This covers classic B2B logistics packaging.

Critical special case — shipping carton: A shipping carton that your end customer opens and removes from the parcel is considered sales packaging, not transport packaging. This applies in particular to own-brand cartons in D2C dispatch. The full requirements of the PPWR apply here, including the digital labelling obligation.

Pure B2B transport (pallet of goods to a retailer, no onward transfer to end consumers) remains exempt from Article 11 obligations, but continues to be subject to the minimisation and recyclability requirements of the Regulation.

For a binding assessment of your specific packaging structure, please contact your responsible Chamber of Commerce and Industry — the initial consultation is free of charge.