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Requirement · RSY-02

Participate in one or more Annex VI Part A re-use systems, recondition reusable packaging per Annex VI Part B before offering it again, and in closed-loop systems return packaging to an approved collection point.

Economic operators using reusable packaging must comply, and this is law in force.

Why it matters

This is law in force, not a proposal.

  • It is Art. 27, in the Packaging and Packaging Waste Regulation. as of 2026-08-18
  • The act gives its timing as: From 12 August 2026 (Art. 71). as of 2026-08-18
  • It names 7 industries by name: Plastics converting, Paper and board, Glass, Aluminium, Wood, Food and drink and Retail. as of 2026-08-18
  • Compliance is checked by re-use system operator, continuous. as of 2026-08-18
Addressee Economic operators using reusable packagingAct Regulation (EU) 2025/40, base actArticle Art. 27Class Businesses

What changes

All users of reusable packaging. Art. 27(3) allows a third party to be appointed to run mutualised systems and to carry these obligations on the operator's behalf.

The rule

New — no predecessor
Trigger

use of reusable packaging

Obligation

Participate in one or more Annex VI Part A re-use systems, recondition reusable packaging per Annex VI Part B before offering it again, and in closed-loop systems return packaging to an approved collection point.

Who is affected

Addressee
Economic operators using reusable packaging
Class
Businesses
Sectors
Names Plastics converting, Paper and board, Glass and ceramics, Aluminium and metals, Wood and wood products, Food, drink and tobacco, Retail and distribution · Reaches Waste and landfill, Hotels, restaurants and catering
Applies
From 12 August 2026 (Art. 71)

Burden drivers

D3 · D5 — 2 of 7 marks fire on this provision.

No size threshold.

Source text

Verbatim

Economic operators that make use of reusable packaging shall participate in one or more re-use systems and shall ensure that the re-use systems within which the reusable packaging can be re-used comply with the requirements laid down in Part A of Annex VI.

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