Back to News 27 March 2026 Understanding PPWR 2025/40: Essential info for Fine Art Logistics New rules are reshaping how art moves across borders. The EU Packaging and Packaging Waste Regulation (PPWR 2025/40) represents a major shift in EU legislation for fine art shipping, as it includes laws on tertiary (transport) packaging, including fine art crating, soft wrapping and pallets. If you’re moving art into or within the EU, it applies to you. See our guide ‘Prepare to Move’ for initial advice by organisation type. “PPWR 2025/40 entered into force in February 2025 and applies from August 2026, and the changes listed below (and more) will be enforced from 1st January 2030.” The regulation harmonises packaging rules across the EU and beyond, transitioning cross-industry practice to circular models by focussing on reuse, recyclability, and accountability. For those working with fine art packaging, fine art logistic and fine art shipping, the biggest change lies in additional reporting requirements, and the move toward structured reuse systems for all transport packaging. What PPWR 2025/40 Means for Fine Art Packaging The regulation introduces specific thresholds for reuse: Imports into the EU: At least 40% of “tertiary” (transport) packaging must be reusable when traveling between “economic operators” within an approved “system of reuse” The remaining 60% must still meet recyclability standards: At least 70% of all packaging must be recyclable in an economically feasible way. Plastic packaging must have at least 35% recycled material content by 2030 and 65% by 2040 Shipments within the EU: Up to 100% reusable transport packaging required between “linked enterprises” anywhere in the EU, or between “economic operators (businesses) within a single member state” must be “reusable within a reuse system”. Exemptions for art packaging include: Multipack objects, (see key dates below for more) Cardboard, as long as it meets recycling content requirements and be recycled after use These rules make reusable crating systems essential for compliance with EU legislation for fine art shipping. ROKBOX LOOP is an example of a reuse system that meets the criteria set out by the EU. What PPWR 2025/40 Means for Fine Art Shipping Under PPWR 25/40, ‘tertiary’ (transport) packaging must increasingly operate within formal “systems of reuse.” These systems are not optional – they are regulated structures with defined requirements: Governance: Clear system operators and rules for participation Design standards: Approved packaging types and specifications Operational processes: Handling, storage, collection, and reconditioning Performance targets: Minimum reuse rotations must be achieved Reporting: Data tracking on reuse cycles, returns, and packaging lifecycle Fair access: Equal participation for all users in the system. This marks a transition from single-use crates to circular, trackable logistics systems. “Reusing a fine art shipping crate will not constitute reuse, unless it is part of a clearly defined and governed ‘system of reuse’.” Extended Producer Responsibility (EPR) A central pillar of the new rules is Extended Producer Responsibility: Mandatory for all businesses placing packaging on the EU market Requires registration with national authorities Mandatory reporting on packaging materials, weight, and recyclability Applies to all packaging types, including tertiary packaging Accountability remains with the organisation commissioning the shipment. Non-compliance can lead to: Border delays Financial penalties Exclusion from reuse systems. “If you move something in packaging to the EU, to a business or a customer, you have to register, regardless of who is paying. Your name will be on it till the end.” When using reusable packaging through a registered Reuse System. ie ROKBOX LOOP, LOOP will provide reporting data for the organisation to submit. Preparing for 2030 Compliance Preparation is critical. Key actions include: Assess current packaging use (reuse vs single-use) Identify actions required, and by when Register for EPR in relevant EU countries Collaborate with reuse system providers ROKBOX LOOP is currently the only established system for art shipping Implement tracking and reporting processes What, by when? From January 2030: All wooden crates will have to be 70%+ recyclable, based on “design for recycling” criteria that will be published in Jan 2028. Much of the current internal cushioning and insulation is not recyclable No single-use wooden crates will be allowed for deliveries between EU businesses Single-use crates will only be permitted for 60% of deliveries to clients (“end users”) and in/out of EU To re-use wooden crates they will need to meet specific design criteria and be deployed within a “reuse system” with defined governance; cost-sharing rules, strict “end of life” recovery and recycling protocols. From 2027: All businesses using packaging within the EU will have to register as “Producers” and for “Extended Producer Responsibility” (EPR) All packaging “Producers” will have to start recording their use and disposal of packaging. From 2028: All packaging “Producers” will have to start reporting their use and disposal of packaging All packaging will have EU Recycling labels, which conform to PPWR rules. From 2029: All reusable packaging will have to implement digital Reuse labelling/QR codes All packaging “Producers” will have completed Packaging Conformity assessments (i.e. validation of their recyclability). From January 1st 2030: 70% of ALL packaging materials must be Recyclable (“in an economically feasible way”) 35% of the raw materials used in Plastic packaging must be Recycled material 40% of “Transport” packaging into and within the EU to be “reusable within a reuse system” Up to 100% of “Transport” packaging to be “reusable within a reuse system” between different sites of a Group or “Linked Enterprise”, anywhere in the EU, and between (un-linked) Economic Operators, shipping within a single member State. 10% of “Grouped Transport” packaging (i.e. crates containing multiple objects) must be “reusable within a reuse system”. Single-use cardboard packaging will still be permitted but subject to recyclability requirements. From January 1st 2038: 80% of ALL packaging materials must be Recyclable (“in an economically feasible way” and “at scale”). From January 1st 2040 65% of the raw materials used in plastic packaging must be recycled material 70% of “Transport” packaging must be “reusable within a reuse system” 25% of “Grouped Transport” packaging (i.e. crates containing multiple objects) must be “reusable within a reuse system”. Planning & Advice Checklist Galleries Audit how often artworks are shipped into or within the EU. Prioritise partners using compliant reuse systems. Ensure contracts clarify EPR responsibility. Speak to ROKBOX about fine art packaging that already complies with recycling and reuse criteria. Museums Align packing standards with PPWR requirements. Integrate reuse systems into loan agreements. Identify local reuse system (see if there is a rok-boxloop.com hub near you). Plan for long-term tracking and reporting of crates and associated packaging. Speak to ROKBOX about fine art packaging that already complies with recycling and reuse criteria. Fine Art Shippers Transition to approved reuse systems for crates. Build internal processes for data tracking and reporting. Educate clients on their obligations under EU legislation for fine art shipping. Speak to ROKBOX about joining the established ROKBOX LOOP network, which already meets the ‘systems of reuse’ criteria. Art Advisors Factor compliance into logistics planning and budgeting. Guide clients toward compliant shipping partners. Understand reuse thresholds when coordinating international movement. Collection Managers Maintain records of packaging types and usage. Coordinate with shippers to ensure data capture for EPR. Monitor compliance across multiple shipments and jurisdictions. Speak to ROKBOX about fine art packaging that already complies with recycling and reuse criteria. A final note PPWR 2025/40 is reshaping fine art packaging into a regulated, data-driven system. Anyone involved in moving art to or within the EU, will need to adapt to these reuse and reporting requirements. Preparing and aligning with EU legislation for fine art shipping now ensures compliance, and future-proofs organisations for other circular economy developments. The EU will publish further definitions and details. ROKBOX will stay up to speed and communicate summaries and resources. Stay safe and stay tuned. Contact Contact ROKBOX +44(0)20 3176 8573 info@rok-box.com Back to News