PPWR for B2B and aerospace packaging: how to assess scope

The Regulation sorts packaging by function, not by customer, and has no general exemption for B2B, industrial or aerospace packaging. Sales packaging forms a sales unit with the product for the end user (Article 3(1), point (5)). Grouped packaging groups sales units at the point of sale, for example as a stock-keeping or distribution unit (point (6)). Transport packaging makes it easier to handle and transport sales units without damage (point (7)). The definition of transport packaging excludes road, rail, ship and air containers, meaning freight containers, not the cases and crates that parts travel in.

A business customer can be an end user. The end user in Article 3(1), point (23) includes a business that uses a product in its own industrial or professional activity and doesn't resell it. So a maintenance shop that fits a part is the end user of that part. If it ordered online or by another distance sale, the outer packaging is e-commerce packaging (point (8)), which carries some rules that other transport packaging doesn't.

Bought-in packaging used between a company's own sites is also in scope. The Commission's FAQ says transport packaging bought from another company and used to move parts between two of the buyer's sites has been placed on the market.

Take a fictional components supplier, Feldane Aero, based in the Netherlands. It ships new and overhauled parts to maintenance shops and aircraft assembly sites in several Member States, and between its own sites. Its packaging falls into six formats.

Small parts, such as seals and fasteners, go in printed cartons that carry Feldane's name and the part label. Each carton is sales packaging, and Feldane is its manufacturer because its name is on it. Pumps and actuators travel in reusable plastic cases with custom-cut foam inserts, which customers send back. Large assemblies travel in single-use wooden crates designed by Feldane's packaging engineers for one part number and built by a crate maker to that design. The Commission's FAQ treats the company that orders unbranded custom-made transport packaging and sets its design as its manufacturer, so Feldane is the manufacturer of the crates.

Cartons going by road are palletised on standard wooden pallets and wrapped in stretch film, both bought in unbranded, so their makers are the manufacturers. Some cartons are filled with loose plastic chips as void fill. Battery units go by road as dangerous goods in UN-approved packaging.

Some requirements apply to every format. The substance rules in Article 5 have applied since 12 August 2026, including the 100 mg/kg limit for lead, cadmium, mercury and hexavalent chromium. So has the duty for the manufacturer to carry out a conformity assessment, keep technical documentation and sign an EU declaration of conformity (Article 15). The FAQ says there is no exemption from these for transport packaging. Minimisation applies to every format from 1 January 2030 (Article 10), and the technical documentation must show the design requirements, such as product protection, that stop further reduction of weight and volume.

Other requirements depend on the format. The harmonised sorting label in Article 12(1) doesn't apply to transport packaging, but it does apply to sales packaging such as Feldane's cartons and to e-commerce packaging, from 12 August 2028 at the earliest. Recycled content targets in Article 7 apply only to plastic parts, such as the cases, inserts and stretch film, from 1 January 2030 at the earliest. From 1 January 2030 or three years after the calculation method, whichever is later, whoever fills transport packaging must keep its empty space ratio at or below 50% (Article 24(1)). Void fill counts as empty space (Article 24(3)), and reusable packaging used in a re-use system is exempt (Article 24(5)).

The reuse targets in Article 29 cover only the formats it lists, which include pallets, boxes, plastic crates, pallet wrapping and straps. From 1 January 2030, at least 40% of such packaging used must be reusable within a re-use system. Moves between a company's own sites, or to another business in the same Member State, must be 100% reusable (Article 29(2) and (3)). Corrugated cardboard boxes are exempt (Article 29(4)(d)). Delegated Decision (EU) 2026/429 lifts the 100% requirement for pallet wrapping and straps, but not the 40% target.

The loose plastic chips have a fixed end date. Article 67(5) adds chips of polystyrene and other plastics used to protect goods in transport to the products banned under the Single-Use Plastics Directive, from 12 February 2029. That ban has no B2B exemption.

The exemption for large-scale machinery, equipment and commodities in Article 29(4)(b) covers packaging that is custom-designed to fit the individual requirements of the company that ordered it. The Commission's guidance notice says a company using it must document that the packaging is custom-designed for an individual product, in the packaging's technical documentation. That documentation covers its design, manufacture and use. The guidance gives no size threshold. Feldane's file for each crate holds the part number, the part's size and mass, the crate drawing and specification, and the reasons for its bespoke features. It also records why the part counts as large-scale equipment. A custom-cut insert for a small part doesn't make that part large-scale.

The dangerous goods exemptions sit in three articles: recyclability (Article 6(11)(f)), recycled content (Article 7(4)(f)) and reuse (Article 29(4)(a)). Each covers packaging used to transport dangerous goods in accordance with Directive 2008/68/EC. The FAQ says they also apply to dangerous goods shipped in limited quantities without UN-approved packaging. UN-approved packaging used for goods that aren't dangerous gets no exemption. Directive 2008/68/EC covers inland transport by road, rail and inland waterway. The Commission's guidance doesn't address packaging used only for air legs, so record the classification of the goods, the packaging approval and the road or rail legs that support the claim.

Some apparent exemptions don't apply here. The exemption for lightweight wood in Article 6(11)(g) covers sales packaging only, not wooden transport crates. The exemption for custom-made transport packaging in Article 15(11) covers configurable medical devices and medical systems only. The FAQ says the ban in point 1 of Annex V doesn't cover B2B situations, but that clarification is about convenience grouping at the point of sale. It doesn't extend to the ban on plastic chips. The FAQ also says exemptions from Articles 6 and 7 must be assessed and recorded in the technical documentation.

Give each format one record. It holds the format and its components, its function (sales, grouped, transport or e-commerce), the manufacturer, the user who fills it and where it travels. List each requirement with its date and the decision: applies, doesn't apply, or exempt. Cite the article for each exemption and link the evidence file.

Feldane's records read as follows. The printed carton is sales packaging, in scope for the substance, recyclability, minimisation, labelling and conformity rules, and exempt from the reuse targets as a cardboard box. The reusable case is in scope for all requirements, counts towards the 40% reuse target, is outside the empty space limit while used in its re-use system, and will need the reusable packaging label. The wooden crate is in scope for all requirements except Article 29, where the custom-design exemption is claimed and the evidence file is linked. The pallet and wrap are in scope for the 40% target. The chips are to be replaced before 12 February 2029. The battery packaging claims the dangerous goods exemptions, with transport records linked.

Date each record and name its owner. Review it when a part, route, customer or packaging supplier changes, and when the Commission adopts the acts on reuse calculation, empty space or design for recycling.