EuPF feedback on the draft delegated decision on reuse targets for pallet wrappings and straps

European Plastic Films (EuPF) has submitted its feedback to the European Commission’s public consultation on the draft delegated act exempting pallet wrappings and straps from the 100 % reuse obligations under Article 29(2) and (3) of the Packaging and Packaging Waste Regulation (PPWR). EuPF welcomes this exemption as an important first step that should not be delayed.

In its submission, EuPF highlights that the latest available scientific, technical and economic evidence also warrants a broader assessment of the continued inclusion of pallet wrappings and straps under Article 29(1). Peer-reviewed life-cycle analysis shows higher greenhouse-gas emissions for reusable alternatives compared to single-use solutions, while technically mature and automated reusable systems are not available at scale and load-safety concerns persist. In addition, independent economic analysis points to significant costs for European industry, including substantial upfront investments and recurring operational burdens, with particular impacts on exporters.

EuPF therefore calls on the Commission, building on the progress made through the current delegated act, to assess the full evidence base in relation to Article 29(1), which supports a format-level exclusion of pallet wrappings and straps from reuse targets under Article 29(1), (2) and (3).