EDANA has co-signed a joint industry statement reacting to the European Commission’s Delegated Act under Article 29 of the Packaging and Packaging Waste Regulation (PPWR).
The Commission’s decision to introduce a derogation for pallet wrappings and straps from the 100% reuse targets set out in Article 29(2) and (3) of the Packaging and Packaging Waste Regulation (PPWR) represents a welcome recognition of the operational challenges consistently raised by the European packaging value chain throughout the legislative process. By acknowledging these practical constraints, the Commission affirms the evidence provided by businesses across sectors, demonstrating that these packaging formats are not suitable for reuse and that, to date, no proven reusable alternatives exist at scale that can guarantee an equivalent level of load stability, product protection, transport safety, and operational reliability. Therefore, the decision to restrict this derogation exclusively to the 100% target, leaving the 40% reuse target of Article 29(1) untouched, is both inconsistent and disappointing.
Maintaining the 40% reuse target under Article 29(1) for these very same formats effectively reintroduces the same concerns regarding feasibility, safety and functionality that were acknowledged in the context of the 100% reuse targets. These challenges arise wherever palletised goods require reliable load securing during transport, storage, and handling. Pallet wrapping films must be cut upon receipt at which point they immediately lose their structural integrity and functional capacity. Similarly, pallet straps are engineered for single-use stabilisation and cannot reliably maintain performance once removed. In many industrial logistics applications, pallets carry very high loads, undergo multiple handling operations, travel long distances, and must meet strict safety requirements. In such contexts, even minor reductions in load-securing performance can create unacceptable risks for workers, compromise product integrity, and endanger transport infrastructure. These challenges are widespread and affect numerous sectors and critical European value chains.
EU Leaders have committed to simplification, enhanced competitiveness, and a regulatory framework that reinforces its industrial base. Granting a targeted exemption from the 40% reuse target for specific transport packaging formats, prioritising recyclability or recycled content where reuse is technically unsuitable, is essential to delivering on these commitments in a coherent and practical manner.
A fragmented approach would lead to a framework that is difficult to apply consistently, raises questions around legal certainty and proportionality, and creates real implementation challenges for companies. We therefore call on the Commission to prioritise the swift adoption of a delegated act exempting pallet wrappings and straps, as well as comparable transport packaging solutions, from the 40% reuse target under Article 29(1), in accordance with Article 29(18)(a) to (c). This is a necessary step to ensure that the PPWR remains workable, proportionate, and fit for purpose.
See all the signatories here
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