New evidence deepens the case against mandatory reuse targets for pallet wrapping

European Plastic Films (EuPF) today published follow-up analyses by ifeu and RDC Environment, deepening and reconfirming evidence that the reuse targets under Article 29(1) of the EU Packaging and Packaging Waste Regulation (PPWR) cannot be justified on environmental, economic or technical grounds.

BUILDING ON AN ESTABLISHED EVIDENCE BASE

Independent studies commissioned by EuPC have consistently demonstrated that single-use plastic pallet wrapping delivers a lower environmental impact than all reusable alternatives assessed, with reusable systems generating greenhouse gas emissions between 35% and over 1,700% higher. A parallel economic impact study found that reuse obligations would impose approximately €4.9 billion in additional annual costs across just eight assessed sectors — a fraction of the industries relying on palletised transport — with the true cost for the wider European economy expected to be substantially higher.

The follow-up analyses commissioned by EuPF and published today specifically address the EU-wide conditions of Article 29(1). The ifeu parameter variation study confirms that the environmental superiority of single-use packaging holds across all distribution distances relevant to EU-wide supply chains. The RDC follow-up study adds that a mandatory transition would require €4.7–5.3 billion in additional capital expenditure and trigger the premature write-off of existing automated machinery with an estimated residual book value of around €1 billion, across the same eight assessed sectors alone.

In a recent response to a parliamentary question, Commissioner Roswall confirmed that the Deloitte feasibility study — which underpinned the Delegated Act — assessed only the 100% reuse targets under Articles 29(2) and (3), not the 40% target under Article 29(1). The study was furthermore unable to assess environmental performance due to insufficient evidence, and explicitly recommended that a dedicated environmental study be commissioned. The ifeu life-cycle assessment is precisely that study. Its conclusions are unambiguous: single-use pallet wrapping is environmentally superior across all applications and all transport distances assessed, including those relevant to transport within the territory of the Union under Article 29(1).

A PARTIAL EXEMPTION LEAVES THE CORE ISSUE UNRESOLVED

The Delegated Act published on 25 February 2026 exempts pallet wrapping and straps from the 100% reuse targets under Articles 29(2) and (3). EuPF welcomes this step, but the 40% reuse target under Article 29(1) — covering transport within the territory of the Union — remains unaddressed. An overwhelming majority of respondents to the public consultation supported extending the exemption to Article 29(1), a position reaffirmed in a joint industry statement signed by more than 80 associations. Despite this broad support, the Commission has not yet acted. At a time when EU competitiveness and regulatory simplification are at the top of the political agenda, pallet wrapping represents a clear opportunity for targeted, evidence-based action.

“The legal and scientific basis for action is unambiguous. The exemption criteria under Article 29(18)(a) and (c) are clearly fulfilled on both economic and environmental grounds. The Commission now has a complete and robust evidence base, and the next step should be a new dedicated delegated act introducing a format-level exemption under Article 29(1).”

— Thomas De Meester, General Manager of EuPF

“Pallet wrapping is a highly optimised packaging material — transparent, lightweight, down-gauged and fully recyclable — continuously refined for efficiency and circularity. Yet Europe’s plastic film industry is navigating significant headwinds. Geopolitical pressures, including trade tensions and supply chain disruptions, are driving up input costs and weighing on demand, while intensifying competition from outside the EU is adding further strain. Against this backdrop, unnecessary regulatory burdens are not a luxury European industry can afford. The Commission’s simplification agenda and the evidence before it point clearly in the same direction. The prospect of mandatory investment in reusable systems that do not yet exist at industrial scale, would increase carbon emissions, and would cost billions across just a handful of sectors, adds a regulatory burden that is as unnecessary as it is disproportionate. We urge the Commission to complete the exemption already partially granted, on the basis of the full evidence now available.”

— Renato Zelcher, President of EuPF and CEO of Crocco

The follow-up studies and a summary of both are available here.