EDANA AISBL

Proposal for a Regulation on Packaging and Packaging Waste EDANA input 1 EDANA, the international association serving the nonwovens and related industries, supports the ambition of the Commission Proposal on Packaging and Packaging Waste Regulation (PPWR) to ensure packaging is designed for circularity, including through the promotion of recycled content uptake. At the same time, we would like to provide our view on some of the provisions of the proposal, namely: I. Packaging of essential nonwoven products should be included in the list of contact- sensitive packaging. The PPWR proposal sets high recycled content targets (35% by 2030; 65% by 2040) on plastic packaging. It also provides that recycled content targets can only be achieved through the use of recycled plastics coming from post-consumer waste (PCR).

…content targets can only be achieved through the use of recycled plastics coming from post-consumer waste (PCR). We are concerned that the high PCR targets set by the current PPWR proposal may increase the risk of migration of substances of concern/contaminants from packaging to product. This could be problematic especially for hygiene products (such as baby diapers and menstrual products (tampons, pads), baby wipes) and for filtration materials, especially if PCR must be used as the base material for packaging materials. Absorbent Hygiene Products (AHP) are intended for prolonged contact with the skin and mucosa of women and children.

Absorbent Hygiene Products (AHP) are intended for prolonged contact with the skin and mucosa of women and children. Given the sensitive application, AHP are covered by several restrictions on substances of concern under EU chemical legislation (REACH).1 Additionally, as EDANA, we developed a voluntary EDANA Stewardship Program (CODEX), going beyond current regulatory requirements, setting maximum voluntary guidance values for numerous substances of concern in AHP. We have evidence that substances of concern may migrate quickly and in substantial quantities from impurities present in PCR to AHP.2 That’s why only very limited quantities of PCR are of sufficient purity to be used in AHP. Our concern is that the high recycled content targets set by the PPWR may force companies to use PCR of insufficient quality and purity, leading to potential safety concerns.

…by the PPWR may force companies to use PCR of insufficient quality and purity, leading to potential safety concerns.  Having lower targets is key to minimizing the risks of companies being forced to use non- suitable PCR, leading to potential migration of substances of concern from the packaging to the product. Given that the exposure of consumers to AHP is similar to their exposure to some medical devices (as an example, adult incontinence products – classified as medical devices – have the same use pattern as baby diapers or menstrual products), we ask for AHP to be considered as “contact sensitive” in the same way as medical devices or food contact packaging.

…we ask for AHP to be considered as “contact sensitive” in the same way as medical devices or food contact packaging. For most contact 1 The exposure hazard classifications under Annex XVII of REACH applicable to AHPs are those with a potential for impact through prolonged skin contact exposure, with associated very low restriction limits for several substances. Additional restrictions are expected in the near future on substances used in childcare articles. 2 One EDANA member company made a test on potential presence of substances of concern in PCR. Based on that, the company could find the presence of phthalates, alkylphenols and bisphenol A across 40 different 25-ton batches of carefully segregated PCR, at levels that were proven to result in detectable migration from the packaging to the product.

…segregated PCR, at levels that were proven to result in detectable migration from the packaging to the product. Based on that, 22.5% of PCR lots had to be rejected, given the significant risks of migration of these substances from the packaging to the product. Ref. Ares(2023)2856206 - 22/04/2023 Proposal for a Regulation on Packaging and Packaging Waste EDANA input 2 sensitive packaging, there are lower recycled content targets (10% by 2030; 50% by 2040) compared to other packaging.  Ensure that also certified pre-consumer plastic waste can be used to achieve the recycled content targets. Under the current proposal, only recycled plastics from post-consumer waste can be used to achieve the recycled content targets. This excludes the possibility to use pre-consumer waste to achieve the recycled content targets.

…content targets. This excludes the possibility to use pre-consumer waste to achieve the recycled content targets. We are concerned that this exclusion will:  Disincentivize the recycling of waste generated in the production processes, leading to increasing risks of incineration of such waste.  Reduce the availability of high quality and pure recycled content that can be safely used in contact sensitive applications. Given lower levels of contamination compared to PCR, pre- consumer waste is an ideal material to be used in AHP packaging.3 II. Recycled content targets need to be established per operator so that a mass-balance approach can be used to facilitate a gradual transition. Indeed, recycled content targets as defined per packaging item may impede the successful transition of all industries to the more recycled content.

…as defined per packaging item may impede the successful transition of all industries to the more recycled content. Certain packaging items/parts will be more difficult to transition to recycled content than others, there will need to be more time, new solutions, and replacements identified for such cases. Therefore, such packaging items/materials cannot comply with the same targets/timelines as other materials. III. Regulators should safeguard the innovation potential of biopolymers. EDANA welcomes the EU Policy Framework on Biobased, biodegradable, and compostable plastics. These materials, if employed and regulated effectively, can play a central role in promoting new technical solutions, reducing the EU’s dependency on fossil carbon resources and can significantly contribute to reducing GHG emissions.

…reducing the EU’s dependency on fossil carbon resources and can significantly contribute to reducing GHG emissions. We therefore believe that the Commission must continue to enable and champion innovation in this field, particularly for applications that are challenging to recycle (e.g., tampon wrappers) and contact-sensitive applications, for which recycled plastic material is a less viable option. EDANA fully supports the inclusion of compostable packaging in the PPWR but calls on the decision- makers to not limit the scope of applications of compostable packaging. We are concerned that such an approach would stifle rather than stimulate innovation and market potential, first and foremost for compostable packaging which can be effectively collected and recycled with other organic waste, but also of other innovative biomaterials which may perform even better in PEF and LCA analyses.

…other organic waste, but also of other innovative biomaterials which may perform even better in PEF and LCA analyses. EDANA therefore calls on regulators to not limit the innovation potential of our industry, where some members are already testing the use of innovative biopolymers to make fully circular products. Limiting packaging applications will result in a smaller market for biopolymers and therefore a significant challenge to make products using them cost-competitive. 3 In contrast to the studies on PCR referenced in 2, the same company’s studies of multiple pre-consumer recycled sources have shown no specific concerns due to the high purity of pre-consumer recycled content. Proposal for a Regulation on Packaging and Packaging Waste EDANA input 3 IV. Transition periods need to be defined for industry to prepare reusable transport packaging.

Waste EDANA input 3 IV. Transition periods need to be defined for industry to prepare reusable transport packaging. Article 26 §7 and §9 requires economic operators to use reusable versions of certain transport packaging, with specific transition periods. Article 26 § 12 and 13, requires the same scope of transport packaging to be 100 percent reusable by the time of entry into force of the Regulation. In order to ensure industry has enough time to adapt the transport packaging to the new requirements, a transition time should be provided. In addition, certain packaging parts that are transformed upon packaging application are not suitable for re-use. Examples mentioned in the PPWR proposal are wrap/shrink and stretch films. V. The benefits of a regulation should not be undermined by provisions whereby Member States can impose further requirements.

…benefits of a regulation should not be undermined by provisions whereby Member States can impose further requirements. It is of great benefit that the new Packaging and Packaging Waste legislation will be regulated union- wide in a regulation compared to the existing situation of many (slightly) different Member States’ individual regulations on that topic. However, the single market principle could still be hampered by the provisions, set in various articles (e.g., Art. 4 §5, Art. 29 §4, Art. 38 §5) which give Member States the option to define more ambitious goals. This may again lead to differences between Member States, which may in turn lead to complications in the supply chain. EDANA therefore advises not to undermine the benefits of the regulation by allowing these provisions. VI.

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Feedback on: Packaging and Packaging Waste – exemptions from the reuse obligations for plastic wrappings and straps Final – 09 - 01- 26 Page 1 of 3 EDANA , the leading global association for the nonwovens and related industries, represents over 270+ member companies across the entire supply chain, including producers of a wide range of packaged goods and, in some cases, contributors to the manufacturing of packaging materials themselves. EDANA would like to provide feedback on the draft Commission delegated Decision supplementing Regulation (EU) 2025/40 of the European Parliament and of the Council (“the PPWR”) by exempting certain economic operators that use pallet wrappings and straps from the 100% reuse requirements of these packaging formats, as published on Have Your Say on 10 December 2025 .

…from the 100% reuse requirements of these packaging formats, as published on Have Your Say on 10 December 2025 . Specifically, EDANA invites the European Commission to: • extend the exemption to the 40% reuse requirement s , which is provided by Article 29, 1. of the PPWR • confirm that cardboard trays fall within the scope of Article 29, 4.

…which is provided by Article 29, 1. of the PPWR • confirm that cardboard trays fall within the scope of Article 29, 4. (d) of the PPWR, which provides that the 40% reuse requirements do not apply to transport packaging or sales packaging in the form of cardboard boxes • clarif y as soon as possible the calculation rules of the re - use targets 1 Indeed, in the current version of the draft Decision , Article 1 provides that: “Economic operators that use pallet wrappings or straps for stabilisation and protection of products put on pallets during transport are exempted from the 100% reuse requirements of these packaging formats established in Article 29(2) and (3) of Regulation (EU) 2025/40 ”.

…reuse requirements of these packaging formats established in Article 29(2) and (3) of Regulation (EU) 2025/40 ”. While EDANA fully supports the Commission’s proposal to exempt e conomic operators that use pallet wrappings or straps for stabilisation and protection of products put on pallets during transport from the 100% reuse requirements , EDANA would like to stress out that the same reasons which motivate the Commission to provide an exemption to the 100% reuse requirements also apply to the 40% reuse requirements. As the draft decision highlights in Recital 4, “ the shift to reusable pallet wrappings and straps would require investments in automated solutions for reusable packaging which are not sufficiently developed yet. Such shift thus might disrupt supply chains and lead to costs to the economic operators, primarily to those who use transport packaging ”. 1 PPWR, Art. 30, 3 Ref.

…and lead to costs to the economic operators, primarily to those who use transport packaging ”. 1 PPWR, Art. 30, 3 Ref. Ares(2026)221693 - 09/01/2026 Feedback on: Packaging and Packaging Waste – exemptions from the reuse obligations for plastic wrappings and straps Final – 09 - 01- 26 Page 2 of 3 Specifically, EDANA would like to kindly remind that: • The nature of customer ordering patterns and manufacturing logistics requires highly flexible and adaptive transport packaging solutions. Single - use plastic wraps and straps are essential to accommodate a broad range of load sizes, shapes, and configuratio ns, from single parcel shipments to mixed or full pallet loads.

…a broad range of load sizes, shapes, and configuratio ns, from single parcel shipments to mixed or full pallet loads. Reusable transport packaging, by contrast, presupposes a level of standardisation that is incompatible with the diversity and complexity of supply chains, particularly for industries that rely on packaging minimisation and tailored fit to reduce environmental impact. Therefore, the need for tailored and flexible transport packaging solutions entails that economic operators that use pallet wrappings or straps can not be bound to a hard 40% reuse obligation. • Single use wraps and straps are not only flexible but also critical to ongoing packaging minimisation strategies. Because they conform to the exact shape and dimensions of the load, they avoid over - packaging and optimise material use.

…they conform to the exact shape and dimensions of the load, they avoid over - packaging and optimise material use. Imposing reuse obliga tions on such formats would undermine innovation aimed at reducing the overall volume and weight of packaging, contrary to one of the core objectives of the PPWR. In addition, c urrent transport packaging format s are appropriate for recycling premises as th e wrapping plastic film is mono material. Recycling of wrapping film is important in order to improve recyclability & PCR rates .

…plastic film is mono material. Recycling of wrapping film is important in order to improve recyclability & PCR rates . Hence the packaging minimisation , the lightweighting and the plastic recycling strategies are not compatible with a 40% reuse obligation for economic operators that use pallet wrappings or straps • According to RDC Environment 2, which conducted an assessment on 8 different sectors, the total estimated annual cost of transitioning from current single - use solutions to reusable alternatives is projected to exceed €4.9 billion across just eight sectors alone. Even if only 40% of pallets are affected, the total cost impact would still be close to €2 billion.

…sectors alone. Even if only 40% of pallets are affected, the total cost impact would still be close to €2 billion. The 40% reuse requirements would entail significant operational changes and capital expenditures, let alone the additional handling, maintenance, and training needs, thus placing economic operators that use pallet wrappings or straps in a disproportionate situation. • Reusable packaging formats occupy substantially more space than single use wraps and straps. This applies not only during reverse logistics (return transport) but also in storage and production areas, which are often tightly constrained. Many facilities lack the space to accommodate the extra volume associated with reusable transport packa ging formats, making compliance impractical without costly restructuring.

…associated with reusable transport packa ging formats, making compliance impractical without costly restructuring. 2 ”Economic impact of switching to reusable options for pallet wrapping”, RDC Environment, Brussels, March 2025 ( link ) Feedback on: Packaging and Packaging Waste – exemptions from the reuse obligations for plastic wrappings and straps Final – 09 - 01- 26 Page 3 of 3 Even with an obligation that is limited to 40% reuse requirements , most facilities would face costly, if not impossible, logical and special constraints • Any change in pallet configuration, particularly involving the securing system, requires re - qualification to ensure safety and performance during transport. This is especially relevant for industries handling sensitive or high - value goods.

…and performance during transport. This is especially relevant for industries handling sensitive or high - value goods. Requiring such v alidation across the entire logistics chain for each variant of reusable wraps and straps would generate significant administrative and financial burdens. As safety of trading goods is a top priority for any undertaking, it is crucial that the European Commission carefully investigates before implementing any new reusable transport packaging format. The current transport packaging format of trading goods wit hin the EU ensures the stability and the protection of products from weather conditions. • Before mandating the reuse of certain packaging formats, it is essential to conduct a thorough Life Cycle Assessment to compare environmental impacts.

…packaging formats, it is essential to conduct a thorough Life Cycle Assessment to compare environmental impacts. Factors such as increased material weight, cleaning, repair, reverse logistics, and end - of- life treatment must be considered. The comparative life cycle assessment conducted by the Institute for Energy and Environmental Research (IFEU )3 suggest s that single - use plastic wraps and straps, due to their lightweight nature and recycling potential, may offer lower overall environmental impacts than reusable alternatives in many use cases. The study indeed indicates that, across all application areas assessed, single - use plastic pall et wrappings outperform reusable transport packaging in every environmental impact category, provided they contain at least 35% post -consumer recycled content, as will be required from 2030 under Article 29 of the PPWR.

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