The European packaging industry has responded with a joint position paper to a delegated act of the EU Commission on the Packaging and Packaging Waste Regulation (PPWR). Numerous industry and packaging associations welcome the planned exemption for pallet strapping and film from the 100-% reuse targets, but criticise the fact that a 40-% reuse target remains in place.
The statement was published in Brussels and signed by a broad alliance of European associations, including representatives from the plastics, paper, glass, chemical and consumer goods industries as well as organisations such as FoodDrinkEurope, Plastics Europe and Fefco.
Industry sees technical limits to reuse
The EU Commission had within the framework of a delegated act to exclude pallet strapping and stretch film from the stricter 100-% reuse targets: Specifically, economic actors that use pallet wrapping or strapping to stabilise and protect goods on pallets will be exempt from the 100 percent reuse targets. in accordance with Article 29(2) and (3) excluded.
Industry associations see this as a recognition of the practical challenges that have been pointed out several times along the European packaging value chain.
According to the industry, this transport packaging is not technically suitable for reusable packaging. Stretch film for pallets has to be cut up after the goods have been delivered and therefore loses its structural stability. Strapping tapes are also designed for single use and cannot reliably fulfil their function after removal.
In many industrial logistics processes, pallets also carry heavy loads, are handled several times and transported over long distances. Even small losses in securing the load could therefore cause risks for employees, products and transport infrastructure.
Criticism of remaining 40 per cent target
The associations criticise the fact that the planned exception should only apply to the 100-% reuse target, while the 40-% target should only apply to the 100-% reuse target. in accordance with Article 29(1) continues to exist. From the industry's point of view, this leads to a contradiction, as the same technical and safety-related problems would also occur with lower reuse rates.
The organisations also warn against fragmented regulation. Different requirements could make implementation more difficult, create legal uncertainty and cause additional burdens for companies along the supply chain.
Demand for complete exemption for transport packaging
The signatories therefore call for pallet films, strapping and comparable transport packaging to also be excluded from the 40-% reuse target. in accordance with Article 29(1) should be excluded. Instead, alternative approaches such as recyclability or the use of recyclates should be given greater consideration if reuse is not technically feasible.
Such an adjustment is necessary to ensure that the PPWR remains „workable, proportionate and fit for purpose“ and at the same time supports the competitiveness of European industry.
Source: EuPC
