Packaging becomes reusable only when a reuse system exists
The PPWR defines a re-use system as organizational, technical or financial arrangements that enable packaging to be collected and reused in closed- or open-loop systems. Users of reusable packaging must participate in such systems and ensure reconditioning before another rotation. Stronger packaging without a reliable return flow can simply become expensive single use.
From 1 January 2030, EU economic operators using pallets, foldable boxes, trays, plastic crates, IBCs, pails, drums and canisters must ensure that at least 40% of transport packaging is reusable within a reuse system; from 2040 they should endeavour toward 70%. Some intra-company and domestic B2B movements face stronger requirements.
The Commission’s 2026 guidance also clarifies imports. Reuse targets apply after goods enter the EU market, from the first warehouse to the final destination when the first warehouse is not the endpoint. Vietnamese exporters therefore need to understand how origin packaging will interface with destination-side reuse pools.
Packaging design must therefore be developed with network design. A crate that does not nest efficiently can make empty returns expensive; a proprietary pallet can be difficult to pool; a non-standard tote can reduce cube utilization. The key question is not only how durable the asset is, but how it returns, through which nodes and at what cost.
The economics depend on rotations, losses and empty returns
The business case is cost per rotation rather than purchase price per unit. A crate costing several times more than a carton can still be cheaper if it completes enough cycles, suffers little damage and returns efficiently. If assets disappear, remain too long at customer sites or travel long empty distances, the reuse advantage can disappear.
Three KPIs matter especially: rotation rate, loss rate and dwell time. Rotation rate measures useful trips per asset; loss rate shows assets that never return or retire early; dwell time measures how long assets remain at each node. A small dwell increase can force a pool operator to buy more equipment even when demand is unchanged.
Pooling converts an individual-company problem into a network problem. Instead of shipper A returning every pallet to factory A, a pool operator can collect near customer B, inspect and repair the asset, then issue it to customer C. The denser the network and the more standardized the asset, the lower the empty repositioning burden.
Data is the second infrastructure layer. GS1 uses the Global Returnable Asset Identifier, GRAI, for pallets, crates, kegs, roll cages and other returnable assets. Barcode or RFID can capture location, rotations, repair history and handovers. Once asset-level records connect with shipment data, packaging becomes a measurable fleet with productivity, maintenance and exception management.
Reusable packaging works only when five flows close together: the asset moves with the goods; data moves with the asset; empties return; packaging is sorted, cleaned and repaired; and the pool is rebalanced to the next point of demand. If one link fails, a company may reduce packaging waste while increasing idle assets, empty mileage or recovery costs. Circular logistics is therefore the operation of a measurable asset network, not simply using the same box many times.
Vietnam: From EPR compliance to packaging-as-an-asset
Vietnam entered a new EPR phase with Decree 110/2026/ND-CP, effective 25 May 2026, detailing producer and importer responsibilities for recycling products and packaging and for waste treatment. Circular 24/2026/TT-BNNMT took effect at the same time. Packaging lifecycle responsibility is therefore becoming more explicit in corporate management.
EPR and reuse are different layers. EPR primarily addresses responsibility when packaging becomes waste; reusable transport packaging delays that point through repeated rotations. For FMCG, food and beverage, components, retail and industrial manufacturing, pooled pallets, plastic crates, totes and metal stillages can reduce one-way packaging at the B2B level.
The best starting point is often a dense closed loop: factory to DC to retailer; supplier to assembly plant; brewery to distributor; fresh produce to supermarket. As participation grows, the pool can become shared. Standard dimensions, quality grades, ownership rules and return procedures are essential if multiple businesses are expected to accept the same asset.
For Vietnamese exporters to the EU, PPWR adds a design consideration. If goods move beyond the first EU warehouse, importers and distributors will increasingly care whether pallets, crates and transport packaging fit an established reuse system. Exporters may not hold the reuse target directly, but origin choices can influence repacking cost and pool compatibility.
3PLs can become operators of this infrastructure. Beyond transport and warehousing, they can offer returnable-packaging-as-a-service: issuing assets, scanning handovers, collecting empties, washing, repairing, grading, rebalancing and reporting rotations. The model fits 3PL networks because they already manage backhaul, cross-docks and shipment data. A mature provider can also set service levels for return time, acceptable damage, cleaning quality and pool availability, turning packaging performance into a contracted logistics KPI rather than an informal warehouse task.
Vietnam’s biggest operational challenge is imbalance: goods move out in concentrated flows while empty assets return in fragmented, seasonal and geographically uneven patterns. A practical roadmap starts with a baseline of asset use and cost, pilots one stable lane, tracks rotations, dwell and losses for six to twelve months, and expands only after the business case is proven. The same data can support deposit rules, chargebacks, seasonal pool sizing and decisions on where repair or washing centres should be located. This is where circular packaging begins to resemble network engineering rather than a procurement exercise.
Reusable packaging is physically small infrastructure with system-wide impact. A pallet or crate does not create circularity by itself; value appears when it completes many rotations inside a dense, standardized and data-visible network. The environmental case becomes stronger when asset utilization is high and empty returns are minimized, because repeated use alone does not guarantee lower system impact.
As PPWR turns reuse into a regulatory target and Vietnam’s EPR framework makes packaging responsibility more explicit, companies need to shift from buy-use-discard toward packaging-as-an-asset. Those that manage rotations, reverse flows and asset data well can reduce waste, working capital and empty kilometres at the same time.
