TIE · Trade and business associations · BE
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PPWR – Exemptions from the reuse obligations for pallet wrappings and straps TIE contribution to the call for feedback 9 January 2026 Toy Industries of Europe (TIE), the association representing the reputable toy manufacturers in Europe, welcomes the opportunity to provide feedback on the exemptions from the reuse obligation for transport packaging and sales packaging used for transport under Regulation (EU) 2025/40 (Packaging and Packaging Waste Regulation – PPWR) for pallet wrappings and straps. TIE members are committed to achieving the sustainable objectives of the PPWR and, more broadly, to contributing to an impactful circular economy. However, the combination of technological limitations, product requirements and competitiveness considerations makes it necessary to review certain targets.
…limitations, product requirements and competitiveness considerations makes it necessary to review certain targets. Regarding pallet wrappings and straps, object of this call for feedback, a general exemption from reuse targets is needed due to, among others: • Safety concerns – Toys are subject to very strict safety rules, and ensuring stable transport between economic operators is essential to ensure product integrity. The choice of protective packaging, including pallet wrappings and straps, is not arbitrary; it must be assessed against safety standards. • Insufficient (affordable) reusable alternatives – At present, reusable alternatives that meet safety requirements are very limited and expensive. Access to such alternatives is restricted to bigger players that can afford higher costs, while smaller realities risk being excluded from the sustainable transition.
…players that can afford higher costs, while smaller realities risk being excluded from the sustainable transition. Even in reusable alternatives were scalable, costs for economic operators would inevitably rise, with obvious consequences for the price of the final product. • Higher environmental impact – With the current reusable alternatives, the risk of product damage during transport would increase, potential making goods unsuitable for sale. This would result in more products being destroyed and, consequently, more waste. The main objective of the PPWR should be to improve sustainability of packaging by supporting the best solution available at scale rather than imposing a unique option. In the case of pallet wrappings and straps, single-use solutions remain the most sustainable choice: they guarantee the highest protection of goods while being highly recyclable.
…remain the most sustainable choice: they guarantee the highest protection of goods while being highly recyclable. TIE fully agrees with the Commission’s proposal to exempt pallet wrappings and straps, regardless of their materials, from the 100% reuse targets set in article 29.2 and 29.3 of the PPWR. At the same time, we remain concerned that, at the current state of technological development, meeting the targets set in Article 29.1 is also unrealistic. For this reason, TIE proposes to extend the material-neutral exemption of pallet wrappings and straps also to Article 29.1. We recommend amending Article 1 of the proposed Delegated Act as follows: Ref.
…and straps also to Article 29.1. We recommend amending Article 1 of the proposed Delegated Act as follows: Ref. Ares(2026)224563 - 09/01/2026 Commission’s proposal TIE proposal Article 1 Exemption concerning pallet wrappings and straps 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. Article 1 Exemption concerning pallet wrappings and straps 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 (1), (2) and (3) of Regulation (EU) 2025/40.
…reuse requirements of these packaging formats established in Article 29 (1), (2) and (3) of Regulation (EU) 2025/40. On a separate but crucial note, we reiterate the importance for economic operators of having sufficient time to familiarise themselves with the new requirements and to adapt internal processes accordingly. TIE urges the European Commission to speed up the development of secondary legislation, guidance and tools to support compliance with the PPWR. The first step must be the quick adoption of exhaustive and sufficiently granular guidelines (Notice and FAQ documents) to support a unanimous interpretation and a smooth implementation of the PPWR.
…guidelines (Notice and FAQ documents) to support a unanimous interpretation and a smooth implementation of the PPWR. Regarding the scope of this call for feedback, TIE members particularly welcome guidance on: • The calculation of reuse targets – although the methodology for calculation is due by 30 June 2027 (Article 30.3), earlier indications are needed on whether the total is calculated per each packaging type or all types listed in Articles 29.1 and 29.2. • Definition of “cardboard box” – to assess exemptions from reuse targets (Article 29.4.d). We remain available to exchange further on this matter. For more information, please contact Andrea-Eleonora Masotto, TIE Sustainability Policy Officer, at [email protected].