A document signed by European Plastics Converters (EuPC), IK Industrievereinigung Kunststoffverpackungen (IK), and Elipso questions the impact of the Packaging and Packaging Waste Regulation’s reuse regulations on plastic pallet wrappings and straps for transporting products – arguing that they already contain post-consumer recyclate, are fully recyclable, and cannot yet be replaced by an effective alternative material.
In the Regulation, reuse is defined as multiple uses of the same packaging for the same purpose – as opposed to recycling, in which waste is re-processed into new materials to be used for the same or a different purpose.
Under Article 29(1), pallet wrappings and straps of any material will be held to a 40% reuse quota when delivering cross-border between independent economic operators from 1st January 2030.
This applies to all listed packaging formats “in total”, the document explains, and companies must report their compliance ‘retrospectively on average per calendar year’. The Commission intends to determine the calculation methods in detail by 30th June 2027.
If a company is delivering products to another economic operator within the same EU Member State or transporting products between different company sites within the EU, they are held to a 100% reuse rate for the packaging formats listed. However, the reuse quotas do not apply to packaging used to transport dangerous goods, large-scale machinery, flexible packaging in direct contact with food or feed, or cardboard boxes.
Under specific circumstances, Member States are also permitted to exempt companies from reuse requirements; and the EU Commission reserves the right to exempt economic operators in the event of “particular economic constraints in a specific sector”, or certain packaging formats facing “hygiene and food safety issues” or “environmental issues”.
According to the document, the final phase of compromise negotiations between the EU Parliament and Member States resulted in reuse requirements being “significantly amended at short notice” in hopes of helping economic operators read and understand the regulations. EuPC, IK, and Elipso believe this process “unintentionally” but “drastically” extended the scope of the 100% reuse quotes compared to the Commission’s original proposal, which impacts pallet wrapping and straps.
They cite the Commission’s former vice president of the European Commission for the European Green Deal, Maroš Šefčovič, confirming in November 2024 that “the full reuse obligation for pallet wrapping and straps is a problem in terms of transport efficiency and safety, economic consequences, including supply chain disruptions and undesirable environmental impacts, among other things.”
Apparently, a delegated act to exempt these packaging formats is being addressed as a “priority”, with the results of a study to prove the exemption requirements expecting in the first half of this year and legally binding exemptions expected in the second.
ISO-compliant life cycle analyses are said to be supported by the European plastic packaging industry. These will compare different packaging units to reusable solutions alongside paper and cardboard variants.
Moreover, the economic consequences of complete reuse obligations are being assessed; the document raises the example that, under current legislation, companies will need to use single-use and reusable packaging systems simultaneously from 2030.
“Plastic pallet wrapping and straps are already fully recyclable today and are largely collected as commercial waste after use and recycled into new films and straps,” the document reads. “They form an important basis for the fulfilment of recycling targets and future minimum recycled content quotas.
“Pallet wrappings and straps already contain a high proportion of post-consumer recyclates. Furthermore, according to the current state of the technology, there is no alternative to plastic pallet wrapping that can secure a load unit with a lower packaging weight and high packaging speed at the same time.
“Against this backdrop, there is great confidence that the EU Commission will initially exempt pallet wrapping and straps from the full reuse obligation in 2025.
“Together with other industry associations, we advocate for revision the reuse requirements for industrial and commercial packaging as a whole. Specifically, we are proposing that the Commission be tasked with presenting a new proposal based on a scientific analysis and impact statement, whereby special quotas for transport between companies in an EU Member State should be waived.”
Sharing the document in a LinkedIn post, Martin Engelmann, director general at IK and a signatory on the document, commented: “After the publication of the EU Packaging Regulation (PPWR) last week, it is clear that some of the rules will never apply as they stand. This applies in particular to the re-use quotas for transport packaging, which have been completely mismanaged in the hectic legislative process.
“As a first step, the Commission has commissioned an expert opinion to justify exceptions for pallet wrapping and strapping bands for pallet protection from the 100% re-use quotas.”
Paolo Bochicchio, managing director at EuPC, and Elipso director general Gaël Bouquet have also signed the document.
The news comes after the partners commissioned a legal assessment from global law firm Dentons. It argued that the PPWR ‘very likely’ violated the EU’s principle of equal treatment by introducing special rules for plastic packaging and exempting other packaging materials, and encouraged the European Parliament to remove material-specific rules in the trilogue negotiations.
IK went on to argue that ‘material-discriminatory’ measures still remained in the provisional PPWR; these included ‘unjustified privileges’ for paper and cardboard and measures that, in its view, resulted in an ‘anti-plastics regulation’. As such, it cautioned that loopholes could contribute to negative environmental impacts and trade conflicts.
Since then, various packaging industry players have sought to replace single-use plastics in transport packaging. Antalis Packaging claims to have developed recyclable, biodegradable paper strapping; Newwen and Paardekooper have come together to distribute reusable polypropylene transport boxes; and 2nd Level Global Solutions has revealed recyclable, 100% paper-based thermal pallet covers for palletized goods.
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