New EU regulation on IBC documentation
Starting August 12, 2026, every IBC counts. Can you provide proof?
If you use plastic or stainless steel IBCs, the deadline is fast approaching. On August 12, 2026, the EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40) will become mandatory. It will apply directly in every EU country, without a national implementing law that would provide additional time.
And IBCs are explicitly included. The regulation classifies large packaging containers, drums, pails, and canisters “of any size and any material” as transport packaging subject to the new rules. The robust stainless steel container is no exception; rather, it is at the center of the regulation: it is precisely these durable, reusable IBCs that are the main target of the regulation.
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What it's about – and what's at stake
The costly misconception is: "My IBC is durable, therefore it's reusable according to the PPWR." This is not the case. The status "reusable" only applies if there is a demonstrably functioning reuse system in place, as defined in Annex VI: collection, proper reconditioning, and redistribution. Anyone placing reusable packaging on the market must provide proof of this system's existence from August 12, 2026 (Articles 11, 26, 27).
If you cannot prove this, you are no longer allowed to declare your containers as "reusable" to authorities and customers – regardless of how robustly they are constructed. Non-compliant packaging risks being flagged during inspections, potentially leading to a sales ban on the EU market. In this case, it's not just a fine that's at stake, but your market access.
Then there's the documentation, and it's quite something.
Every unit must be identifiable , every cycle , every cleaning , every repair traceable and accessible upon request from authorities. And not just for a few months: Article 15 stipulates a ten-year retention period for reusable packaging from the date it was placed on the market (five for single-use). IBCs are reusable, so the full ten-year period applies continuously. Anyone attempting to manage this with Excel spreadsheets and email attachments over ten years, across multiple locations and changing service providers, will be caught in an audit. Not out of malice, but simply because such documentation is not auditable.
There are still some days left until the deadline. Anyone who doesn’t start now will be operating their fleet from August onward without the foundation required by law.
The timetable of the regulation – and what it means for your fleet
The PPWR is being implemented in stages. Five dates are relevant for IBC operators, three of which are mandatory, while two others depend partly on pending legislation:
What the regulation requires
What this means for you
August 12, 2026
Reusable packaging must be part of a functioning reuse system in accordance with Annex VI (Articles 11, 26, 27). Traceability and documentation must commence. The declaration of conformity and technical documentation must be retained for ten years for reusable packaging (Article 15).
Every IBC needs a unique identity and a complete digital history, accessible for over ten years.
February 12, 2027
The first digital labeling requirements under extended producer responsibility. Minimum rotation numbers and calculation methods for the quotas are being specified. Much depends on delegated and implementing acts that the Commission will adopt.
Once the values are established, the number of cycles per unit must be recorded and compared against minimum requirements. Those who already have the system counting are prepared.
February 12, 2029
Reusable packaging must bear a marking indicating its reusability, optionally via a QR code or digital data carrier. This includes reusable IBCs. (The harmonized sorting marking according to Article 12, however, does not apply to transport packaging, except in e-commerce.)
Each unit needs a machine-readable carrier that links to the stored history.
January 1, 2030
A minimum of 40% reuse rate for transport packaging, specifically IBCs (Art. 29 para. 1). 100% reuse for transport between company sites (Art. 29 para. 2). Maximum 50% empty space when filled (Art. 24). Annual reporting obligation regarding rates and circulation.
Count the number of cycles per container, compare against the quota, and export to the authorities at the touch of a button.
January 1, 2040
Target value of 70% reusable packaging for transport packaging (Art. 29 para. 1). Stricter requirements for recyclability and recycled content.
Without continuous tracking from today onwards, the data basis will be missing in 2040.
One point that many overviews omit: The 40% target from 2030 onwards is mandatory , while the 70% target from 2040 is a goal. However, this doesn't alleviate the pressure from 2026. The obligation to implement a reuse system and provide documentation takes effect on August 12, 2026. By 2030, you will simply be demonstrating what is already required by then.
And this is precisely where the real opportunity lies: Those who establish a solid database foundation in 2026 won't have to chase after every single deadline. Identity, cycles, and reconditioning data for each container are recorded once, and then the same data is carried over to 2027, 2029, and 2030. In contrast, those who treat each deadline as a separate project will be building the data structure, supplier integration, and labeling system under time pressure, all in parallel. That will be expensive.
How ibc.digital takes this burden off your shoulders
This is precisely where ibc.digital comes in, a modular solution from NXTGN Solutions GmbH in Neumarkt, Germany, resulting from a partnership between BASF, NXTGN, and CONTEK IBC Service GmbH. The platform maps the complete turnaround of an IBC, from empty to empty: filling, transporting, emptying, cleaning, repairing, testing, releasing, and refilling. This is exactly the reconditioning process that Annex VI requires to be documented. What the regulation mandates is achieved here as a byproduct of daily operations. You decide how deeply you want to delve into the process.
Quickly testable, without a long lead time.
The system is accessed via the app with integrated QR code management. Each IBC receives an identity, every cycle is recorded, and every reconditioning process is documented. This provides the required documentation according to Annex VI without requiring you to equip your entire fleet with sensors first. This keeps initial costs low and gets you ready for inspection before August 12th.
Hardware only where it makes financial sense.
Containers that require more than just a QR code are equipped with suitable trackers: RFID for presence detection, LIME (GPS, temperature), MOCCA (for aseptic IBCs), IRIS (fill level without tampering with the container), plus versions for heated and bioprocess containers. An early warning system also notifies you of upcoming deadlines, such as ADR inspections, before they result in a violation. This way, you only pay for sensors where the process requires them.
Grow with the times instead of rebuilding.
The app runs as a Power App in Microsoft 365, both in the office and in the field. A connector allows you to integrate your ERP or CRM system, whether SAP, Microsoft Dynamics, JD Edwards, or Navision. It's not a standalone solution, but rather an extension of what you already use.
A platform for all participants.
Creating orders, documenting routes, approving quality, sharing evidence: manufacturers, dealers, customers, freight forwarders, poolers, and reconditioners all work with the same data. This is precisely what Annex VI means by a closed, traceable cycle. Faxes and email chains do not meet this requirement.
What elevates this investment beyond mere compliance: The same data you need for the PPWR (Product and Service Record) makes the Total Cost of Ownership of your fleet visible. Downtime, repair and cleaning costs, shrinkage, demand forecasting. The obligation to document becomes a management tool.
And there's a revenue side. Your IBC pool can be operated as a rental model via the service portal. Container manufacturers, fillers, and processing companies all share a common database, and the customer can intervene if necessary, for example, in the event of a breakdown or if a container empties earlier than planned. The obligation to demonstrate a reusable container system thus becomes a viable business model.
What you should do now
Start with a clear inventory. How many IBCs are in circulation? What is the current reuse rate? And how is the life cycle currently documented, if at all? This will reveal your gap as of August 12, 2026. In most cases, the path to that date is shorter than those involved initially fear – provided you start now.
Let's review your fleet together and determine the fastest way to get it into an inspection-ready condition.
This article summarizes the requirements of Regulation (EU) 2025/40 (PPWR) and serves for general information purposes only. It does not constitute legal advice. The applicable text of the Regulation is authoritative (including Articles 11, 15, 24, 26, 27, 29 and Annex VI). Individual deadlines may be subject to change through delegated and implementing acts.
The direct link to the regulation is: https://eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=OJ:L_202500040
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