FIBCs under the PPWR: Our interpretation of reuse requirements and next steps

PPWR will fundamentally change how packaging is designed, used, and reused in Europe from 2030 onwards.

Many stakeholders are now asking what this means for Flexible Intermediate Bulk Containers (FIBC’s / Big Bags).

Our assessment
The way FIBCs are currently designed and used in industrial supply chains means they should not fall under the specific PPWR reuse requirements for transport packaging or “sales packaging used for transporting products”.

We have prepared a short interpretation note to:

Explain how FIBCs are typically used as industrial sales packaging
Show why realistic reuse is often technically or hygienically not feasible
Clarify what this means for end users of FIBCs under PPWR

FIBCs under the PPWR: Why current uses are out of scope of reuse rules.

Our Interpretation for Legislators and Customers

By: The Royal NNZ Group, Groningen. Technopac, Wilhelmsburg.

Date: 17^th Feb 2026

Introduction

The EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) introduces new reuse obligations from 2030 for certain packaging types, with important consequences for many industrial supply chains. Many customers and policymakers are therefore asking whether Flexible Intermediate Bulk Containers (FIBCs, “Big Bags”) will be covered by these specific reuse rules and what this would mean in practice.

Based on the current regulatory text and available guidance, our assessment is that typical FIBCs used today in industrial and commercial applications should not fall under the PPWR reuse provisions for transport packaging or “sales packaging used for transporting products”. The purpose of this document is to explain this interpretation in clear terms, to support informed dialogue with legislators and authorities, and to give our customers orientation while not replacing individual legal advice.

How FIBCs are used today

In practice, filled FIBCs are delivered directly to professional end users (industrial, commercial or agricultural operators) as a ready to use sales unit and are normally not repacked before use. The filled FIBC itself forms the sales unit as it is the container in which the customer receives and uses the product.

FIBCs perform several key functions during their lifecycle:

Sales and presentation function: FIBCs are supplied filled, often with product identification, batch information, regulatory data and brand information printed on the bag. They are presented to the professional end user in this form and constitute the packaging-product unit at the end user’s location.
Protection and storage function: FIBCs protect sensitive contents (such as food ingredients, dairy powders, chemicals, pharmaceutical intermediates or fertilisers) against moisture, contamination, light, oxygen and other environmental impacts. They are frequently used as long-term storage units in warehouses or on farms, where their robust construction (coatings, liners, dimensional stability) allows space, saving and secure stacking.
Handling and internal logistics function: FIBCs are specifically designed for safe filling, lifting, dosing and emptying by means of lifting loops, tailored inlet and outlet constructions, and compatibility with common warehouse and production handling systems (forklifts, hoists, dosing stations). These design features serve internal logistics within the end user’s operations, not repeated external transport cycles.

Why current FIBC uses are not in scope of PPWR reuse rules

The PPWR introduces reuse obligations from 2030 for certain packaging types, specifically including “transport packaging” and some categories of “sales packaging used for transporting products”. However, the classification of a packaging format under these provisions depends primarily on the function the packaging predominantly performs. In particular whether it has an evident and primary transport function, rather than on its physical form or the fact that it is transported.

In our assessment, typical FIBCs do not qualify as “transport packaging” or “sales packaging used for transporting products” for the following reasons:

Predominant function is not transport

FIBCs are industrial or commercial sales packaging, not transport packaging. The filled FIBC is the sales unit supplied directly to the professional end user and usually is not repackaged. While FIBCs are certainly transported, this transport function is secondary to their role as packaging that contains and protects the product during storage and use at the end user’s location. The design and construction of FIBCs optimise their role as protective storage and handling packaging for bulk materials, not their role as reusable transport containers for multiple trips.

Technical infeasibility of reuse in many applications

In many industrial sectors, FIBCs are emptied in a destructive manner. For example, in construction (sand, gravel, dry mortar) and agricultural (fertilisers) applications, FIBCs are often emptied by lifting and cutting open the bottom of the bag. Once emptied this way, the FIBC cannot be reused.

Hygiene and environmental constraints for sensitive products

Where FIBCs are used for food ingredients (sugar, milk powder, infant formula), pharmaceutical intermediates, chemicals or other sensitive products, realistic reuse would require intensive cleaning to remove all residues and odours from the interior. Such cleaning processes would consume significant amounts of water, energy and chemicals, making them technically complex and environmentally disproportionate as a standard reuse model. The PPWR itself recognises in the Commission’s guidance that such intensive cleaning would not constitute a feasible option for many types of sales packaging.

Implications for end users under PPWR

It is important to note that the PPWR reuse obligations apply to “economic operators” who use the specified reusable packaging formats. These obligations do not apply to “end users” who receive and use filled packaging in the course of their activities.

An end user, under PPWR definitions, is any natural or legal person established in the EU to whom a packaged product is supplied by another person, and who does not reintroduce that packaged product to the market in the form supplied to them.

A company that receives filled FIBCs and empties them in the course of its industrial, commercial or agricultural activities is therefore, in our understanding, an end user and is not legally obliged under Articles 29(1)–(3) PPWR to reuse these FIBCs.

Next Steps

We will continue to monitor legislative developments, implementing acts and guidance related to the PPWR and will adjust this interpretation if the regulatory framework evolves.

Stakeholders are encouraged to:

Review their own use of FIBCs and assess how the PPWR may affect their operations
Consult internal or external legal counsel where appropriate to verify their specific regulatory position
Engage in dialogue with industry associations and regulators to ensure legal certainty and practical, sustainable solutions for the circular economy

Disclaimer

This text represents our reasoned interpretation of the PPWR based on the current regulatory text and available guidance. It is non-binding, and does not constitute legal advice. Each operator remains responsible for verifying its own regulatory situation and seeking individual legal counsel where necessary. We do not accept liability for the application of this interpretation to specific circumstances.