European Industry Associations Urge Exemption from PPWR Reuse Targets for Pallet Wrappings and Straps

Industry associations have issued a response to the European Commission’s Delegated Act under Article 29 of the Packaging and Packagaing Waste Regulation (PPWR). The statement addresses reuse targets for pallet wrappings and straps and highlights operational and technical considerations.

The European Commission’s decision to introduce a derogation for pallet wrappings and straps from the 100% reuse targets outlined in Article 29(2) and (3) of the Packaging and Packaging Waste Regulation (PPWR) acknowledges operational challenges highlighted by stakeholders across the European packaging value chain during the legislative process. According to the joint statement, evidence submitted by businesses indicates that these packaging formats are not suitable for reuse and that no scalable reusable alternatives currently provide equivalent performance in load stability, product protection, transport safety, and operational reliability.

However, the decision to limit the derogation to the 100% reuse target, while maintaining the 40% reuse requirement under Article 29(1), is described as inconsistent. The statement notes that retaining the 40% target for the same packaging formats raises similar concerns regarding feasibility, safety, and functionality.

The associations outline that pallet wrapping films lose structural integrity once cut during unloading, while pallet straps are designed for single-use stabilisation and cannot maintain performance after removal. In industrial logistics, pallets often carry high loads, undergo repeated handling, and travel long distances under strict safety conditions. Any reduction in load-securing performance may pose risks to workers, affect product integrity, and impact transport infrastructure. These challenges are reported across multiple sectors and European value chains.

The statement also refers to commitments by EU leaders to simplify regulations, enhance competitiveness, and strengthen the industrial base. It highlights that granting an exemption from the 40% reuse target for certain transport packaging formats, while prioritising recyclability or recycled content where reuse is not technically viable, would align with these objectives.

Concerns are raised that a fragmented regulatory approach could complicate consistent implementation, create uncertainty in legal interpretation, and increase operational challenges for companies. The associations call on the Commission to adopt a delegated act that exempts pallet wrappings, straps, and similar transport packaging solutions from the 40% reuse target under Article 29(1), in line with Article 29(18)(a) to (c).

The statement concludes that such a measure is necessary to ensure the PPWR framework remains practical, proportionate, and workable.

The joint statement is supported by multiple European and national industry associations across sectors including packaging, plastics, chemicals, retail, manufacturing, and consumer goods.