ECC · Trade and business associations · BE
European Federation for Construction Chemicals - Rue Belliard 40 - 1040 Brussels, Belgium; [email protected] - www.efcc.eu European Federation for Construction Chemicals EFCC’s reply to Public Consultation on Packaging and Packaging Waste – exemptions from the reuse obligations for plastic wrappings and straps (delegated act) 8 January 2026, Brussels Introduction The European Federation for Construction Chemicals (EFCC) welcomes the opportunity to provide feedback on the draft Commission Delegated Decision supplementing Regulation (EU) 2025/40 on packaging and packaging waste. EFCC represents companies that are directly affected by the reuse obligations for transport packaging under Article 29 of the PPWR. Our members have extensive practical experience with pallet wrappings and strapping used to ensure product safety, transport stability, and supply-chain efficiency.
…with pallet wrappings and strapping used to ensure product safety, transport stability, and supply-chain efficiency. Based on this experience, we would like to share the following key considerations. Key Statement / EFCC Position We welcome and support the European Commission’s reflection on exempting straps and stretch films from the 100% reuse obligations under Article 29(2) and (3) of the PPWR. This approach is essential to avoid disproportionate adaptation costs for operators and to allow resources to be directed toward measures with higher environmental impact. However, the current proposal has a significant shortcoming: it only addresses Articles 29(2) and (3) and does not include cross-border transport reuse targets under Article 29(1).
…it only addresses Articles 29(2) and (3) and does not include cross-border transport reuse targets under Article 29(1). As a result, industry would still be required to introduce measures to meet these targets and would therefore not fully benefit from the proposed exemption. This would maintain high administrative costs and could also introduce transport safety risks, given the lack of viable and widely available alternatives. Furthermore, existing life-cycle impact assessments indicate that thermal recovery of packaging often delivers better environmental outcomes than reuse, particularly when additional cleaning requirements and increased transport distances associated with reuse systems are taken into account.
…cleaning requirements and increased transport distances associated with reuse systems are taken into account. Given these factors, EFCC strongly recommends that: • Stretch wrap and strapping be either excluded from the scope of the PPWR altogether, or • Addressed under a tailored regulatory framework that recognises their safety- critical role and the absence of practical, environmentally sustainable reuse alternatives. Ref. Ares(2026)227273 - 09/01/2026 European Federation for Construction Chemicals - Rue Belliard 40 - 1040 Brussels, Belgium; [email protected] - www.efcc.eu European Federation for Construction Chemicals About EFCC The European Federation for Construction Chemicals (EFCC), headquartered in Brussels, represents over 80% of the companies and national federations active in the European construction chemicals sector.
…over 80% of the companies and national federations active in the European construction chemicals sector. In 2024, the European construction chemicals market was valued at approximately €20.5 billion. Construction chemicals are essential to improving the performance, durability, and sustainability of Europe’s built environment. EFCC members manufacture concrete admixtures, mortar systems, sealants, adhesives, waterproofing solutions, flooring systems, anticorrosion agents, and other key additives that enhance construction quality and efficiency. For further information please contact: European Federation for Construction Chemicals Andrea Nam, Director General [email protected] EFCC website: http://www.efcc.eu