The European Plastic Films Association (European Plastic Films, EuPF) welcomes the European Commission's adoption of a delegated act exempting economic operators from the 100% reuse obligation for pallet wrapping films and straps under Article 29(2) and (3) of the Packaging and Packaging Waste Regulation (PPWR). The exemption applies to palletised transport between interlinked companies in the European Union and between companies in the same Member State. The act also clarifies that these uses are not subject to the 40% reuse target set out in Article 29(1).
At the same time, pallet wrapping film used in cross-border transport between different economic operators located in two EU Member States remains subject to the reuse requirements under Article 29(1). In EuPF's view, this is a missed opportunity to address documented environmental, economic and operational aspects associated with this transport segment.
Scope of the exemption and EuPF position
Under the adopted delegated act, the 100% reuse requirement will not apply to pallet films and straps used in domestic and intra-group palletised transport covered by Article 29(2) and (3) of the PPWR. At the same time, the Commission indicated that these applications are excluded from the 40% reuse target set out in Article 29(1). This means that in these areas it is possible to continue using single-use, recyclable plastic solutions without the need to meet a specific reuse level.
EuPF points out that other applications of pallet wrapping film, in particular in cross-border transport between different economic operators located in two Member States, remain subject to the reuse target under Article 29(1). According to the association, this leaves aside an area where the reuse obligation is associated with significant environmental and cost implications.
As EuPF head Thomas De Meester stressed: "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(1). Ignoring this risks higher emissions, billions in additional costs and ultimately undermines the competitiveness of European industry."
Broad cross-sector support
Pallet wrapping films and straps play a key role in ensuring safe, fast and automated logistics across virtually all industrial sectors and supply chains in the Union. During the public consultation, stakeholders from various branches of the European economy expressed strong support for extending the exemption to applications covered by Article 29(1) of the PPWR.
In their submissions, they consistently highlighted concerns related to environmental performance, economic and operational feasibility, as well as safety and load stability. This shows that the issue does not concern a single material or a single sector, but directly affects the functioning of palletised transport across the entire economy of the European Union.
Environmental impact confirmed by life-cycle assessment
An independent life-cycle assessment (LCA) indicates that a shift from currently used single-use, recyclable film solutions to reusable packaging systems may lead to an increase in greenhouse gas emissions from approximately 35% to more than 1700%. This increase is mainly due to the use of heavier materials, lower pallet space efficiency and the need for additional transport associated with reverse logistics and cleaning processes.
Article 29(1) refers to cross-border transport within the EU, which generally involves longer distances than in domestic scenarios. The data collected confirm that as routes become longer, the environmental burdens arising from the operation of reusable packaging systems also increase.
Scale of economic consequences
An economic analysis covering eight key sectors, including agriculture, cement, construction, milk, glass, plastics, retail and bottled water, estimates additional annual costs at around EUR 4.9 billion. In order to enable the use of reusable pallet packaging systems in these industries, additional capital expenditure of between EUR 4.7 and 5.3 billion would be required, beyond standard equipment replacement cycles.
The analyses also show that implementing such systems would result in the premature decommissioning of automated equipment with an estimated total residual value of around EUR 1 billion at EU level. Due to the cross-sectoral use of palletised transport in many branches of the economy, the overall economic impact at the EU level would be significantly higher than the values calculated for the eight sectors analysed.
Export-oriented companies would be particularly affected. In practice, the return of reusable pallet packaging from third countries is, in many cases, not feasible. Companies operating both on the EU market and outside it would therefore have to run two packaging systems in parallel, which means higher operating costs and process complexity. From EuPF's perspective, the exemption criteria related to environmental impacts and economic constraints are clearly met in this case.
Competitiveness, regulation and call for reassessment
The need to reconcile environmental ambitions with industrial realities has been one of the main themes of recent political debates, including the Antwerp European Industry Summit, which focused on competitiveness and regulatory simplification. Maintaining the reuse target under Article 29(1) without reassessing the available data may, in EuPF's view, weaken the competitiveness of EU industry, increase the complexity of legal requirements and discourage investment in efficient and recyclable packaging solutions.
In light of the analyses presented, EuPF calls on the European Commission to reassess the available scientific evidence and, if necessary, to prepare a further delegated act addressing Article 29(1) of the PPWR. The association stresses that further regulatory decisions in the field of pallet packaging should consistently take into account environmental and economic aspects, as well as the safety and continuity of supply chains throughout the European Union.
