100% Reuse Exemption for Pallet Wrapping and Strapping: What Changes in Logistics

Key data

If your company moves goods on pallets, this regulation affects you directly. The Delegated Decision (EU) 2026/429, published on 6 May 2026, establishes that operators using wrappings and strapping to secure pallets are exempt from the 100% reuse objective required by Regulation (EU) 2025/40.

The reason is technical and operational: the Commission recognizes that these packaging formats have characteristics that make it unfeasible or disproportionate to require their full reuse. This provides legal certainty to a sector that had already identified practical barriers to meeting that objective.

The key lies in two words: specific exemption. It is not a general waiver of the Packaging Regulation, but a concrete release from the 100% reuse requirement for these materials. The remaining obligations under Regulation (EU) 2025/40 continue to apply normally.

What does this regulation establish?

Regulation (EU) 2025/40 on packaging and packaging waste imposes reuse objectives on economic operators for certain packaging formats. Among them, the 100% reuse requirement for pallet wrappings and strapping.

Delegated Decision 2026/429 complements that Regulation with a specific exemption. Its logic is clear: if the reuse of a packaging format is technically or operationally unfeasible or disproportionate, there is no point in maintaining the obligation.

The regulation does not eliminate operator responsibility: anyone wishing to benefit from the exemption must be able to demonstrate that they meet the established criteria, especially during inspections.

Economic and operational impact

For affected companies, this exemption has a direct and relevant operational impact. Adapting logistics processes to 100% reuse stretch film and pallet strapping would have required significant investments in collection, cleaning, storage and redistribution systems for these materials.

The exemption avoids those adaptation costs. But it generates a new management obligation: documenting that the company meets the criteria to benefit from it. Without that documentation, the company cannot invoke the exemption during an inspection and would be exposed to the general regime of Regulation (EU) 2025/40.

• Cost avoided: Investment in stretch film and strapping reuse infrastructure.
• New cost: Internal process for verifying criteria and documenting the exemption.
• Residual risk: Non-compliance with the remaining obligations of Regulation (EU) 2025/40, which remain in force.
• Opportunity: Legal certainty for operators already operating without reuse systems for these materials.

Who does it affect?

The regulation directly affects economic operators using wrappings and strapping to secure pallets in their operations. This includes:

• Logistics operators: transport, storage and distribution companies that palletize goods with stretch film or strapping.
• Distributors: wholesalers and distributors that prepare pallets for shipment to customers or retail points.
• Manufacturers: industrial companies using stretch film or strapping on their packaging and shipping lines.
• Supply chains: any operator that at any point in their production or logistics process uses these materials for pallet securing.

If your company uses stretch film or strapping at any point in your supply chain, this regulation affects you and you should review your situation.

Practical example

Imagine a food distribution company that prepares 500 pallets daily for shipment to supermarkets. Each pallet is wrapped with stretch film and secured with plastic strapping before loading.

Under Regulation (EU) 2025/40, this company would be obligated to reuse 100% of that film and strapping. In practice, this would involve recovering materials at each delivery point, transporting them back, cleaning them, inspecting them and reintegrating them into the process. A complex and costly operation for materials that, by their nature, deteriorate with use.

With Delegated Decision 2026/429, this distributor is exempt from that specific requirement. What it must do now is: verify that it meets the exemption criteria, document it in its internal records and ensure that the remaining obligations of Regulation (EU) 2025/40 are correctly met. If an inspection comes, that documentation is its legal backing.

What should companies do now?

1. Identify if you use wrappings or strapping for pallets at any point in your supply chain or production process. If so, this regulation applies to you.
2. Review the eligibility criteria of Delegated Decision 2026/429 to confirm that your operation fits the exemption. It is not enough to use these materials: you must meet the specific criteria of the regulation.
3. Document internally the compliance with the exemption criteria. This documentation is essential during potential inspections. Without it, you cannot invoke the exemption.
4. Review the remaining obligations of Regulation (EU) 2025/40 that remain in force for your company. The exemption is specific to the 100% reuse requirement for these materials, not a general waiver.
5. Consult with a specialist advisor in packaging regulations if you have doubts about eligibility criteria or how to properly document the exemption in your specific case.