Exemptions for wrapping film and straps, for EuPF the reuse target remains unresolved

European Plastic Films (EuPF), the sector group within EuPC representing Europe’s plastic-film converting industry, welcomes the European Commission’s adoption of the delegated act exempting economic operators from the 100% reuse obligations for pallet wrapping and straps under Article 29 of the Packaging and Packaging Waste Regulation (PPWR), which apply to palletised transport between interlinked companies within the EU and between companies in the same Member State. The act also clarifies that these uses are not subject to the 40 percent reuse quota under Article 29. However, pallet wrapping used for cross-border transport between different economic operators in two EU Member States remains subject to Article 29. In EuPF’s view, this is a missed opportunity to address well-documented environmental, economic and operational concerns.

“The Commission has acknowledged that a blanket reuse obligation for pallet wrapping is not workable in domestic and intra-group transport. The same evidence applies to intra-EU cross-border transport under Article 29. Ignoring this risks higher emissions, billions in additional costs and ultimately undermines the competitiveness of European industry,” said Thomas De Meester, Head of EuPF.

Pallet wrapping films and straps are essential for safe, high-speed and automated logistics across virtually all industrial sectors and supply chains in the Union. During the public consultation, stakeholders from across European industry expressed overwhelming support for extending the exemption to Article 29, consistently highlighting concerns related to environmental performance, economic and operational feasibility, safety and load security. The issue therefore affects not only one material or sector, but the functioning of palletised transport across the entire EU economy.

An independent life-cycle assessment shows that switching to reusable alternatives can increase greenhouse-gas emissions by approximately 35% to more than 1,700% compared with existing recyclable single-use solutions, mainly due to heavier materials, reduced pallet efficiency and additional transport for return and cleaning. Article 29 targets cross-border transport within the EU, where distances are longer than in domestic scenarios, and the data confirms that environmental impacts rise accordingly.

Economic analysis across eight key sectors – agriculture, cement, construction, milk, glass, plastics, retail and bottled water – estimates additional annual costs of around 4.9 billion euros. Enabling reusable pallet packaging capability across these sectors would require between 4.7 and 5.3 billion euros in additional capital expenditure beyond normal replacement cycles and lead to the premature replacement of automated equipment with an estimated residual value of around 1 billion euros at EU level. Given the cross-sectoral use of palletised transport, the overall economic impact across the EU economy would be significantly higher.

Export-oriented companies would face particular challenges, as reusable packaging cannot realistically be returned from third countries. Businesses active both inside and outside the EU would therefore need to operate parallel systems, increasing costs and operational complexity. In EuPF view, the exemption criteria relating to environmental issues and economic constraints are clearly fulfilled.

The need to reconcile environmental ambition with industrial reality has been strongly emphasised in recent political discussions, including at the Antwerp European Industry Summit, where competitiveness and regulatory simplification were central themes. Maintaining the reuse target under Article 29 without reassessment risks undermining EU competitiveness, increasing regulatory complexity and discouraging investment in efficient and recyclable solutions. EuPF therefore calls on the Commission to reassess the available scientific evidence and, if necessary, introduce a further delegated act addressing Article 29.