In principle you do, if you are the shipper: the regulation covers economic operators using transport packaging to deliver, and in our reading a customer's contractual requirement is not among the exclusions. Examine three options before reaching a conclusion. First, check whether some flows are excluded by Article 29, paragraph 4: dangerous goods, custom packaging and flexible formats in contact with food. Next, distinguish domestic flows, which must be 100% reusable in 2030, from deliveries to other Union countries, subject to 40%. Finally, consider pooling: the rental provider collects the pallet from your customer, who has nothing to send back to you. Before deciding, discuss hygiene constraints with the pooler, such as those at sites handling animal by-products.
Read the source article: PPWR reuse targets: packaging categories and 2030 quotas