IMA-Europe · Trade and business associations · BE
Industrial Minerals Association Europe Rue des Deux Eglises 26, Box 2, BE-1000 Brussels, Belgium Transparency registry number: 14190001484-01 Contact us: [email protected];www.ima-europe.eu IMA-Europe consultation response Draft Delegated Decision – supplementing Regulation (EU) 2025/40 by exempting certain economic operators that use pallet wrapping and straps from the 100% reuse requirements of these packaging formats Final (09.01.2026) The Industrial Minerals Association Europe (IMA-Europe), representing the interest of Industrial minerals producers in Europe, welcomes the European Commission’s initiative to exempt plastic pallet wrappings and straps from the 100% reuse obligation of the Packaging and Packaging Waste Regulation (PPWR), as highlighted below.
…straps from the 100% reuse obligation of the Packaging and Packaging Waste Regulation (PPWR), as highlighted below. Article (1) of the proposed Delegated Act: 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. This exemption reflects a pragmatic understanding of the logistics supply chain and technical and economic realities. For the industrial minerals sector, the safety and stability of heavy loads during transport are critical. Currently, alternative materials, such as compostable solutions, are very expensive and often lack the mechanical properties required for industrial applications, rendering them economically and operationally infeasible at this stage.
…required for industrial applications, rendering them economically and operationally infeasible at this stage. In addition, IMA-Europe would also encourage the Commission to consider an exemption for transport packaging from the 40% reuse requirement (Article 29(1) of Regulation (EU) 2025/40). As outlined in the Commission’s draft Delegated Act (Recital 4), there is a confirmed technological gap for the shift to reusable transport packaging. In this context, the technical inability of plastic film to be reused can lead to safety risks, regardless of whether the transport is internal (Article 29(2)) or external (Article 29(1)). The latter regulates transport packaging between different economic operators, often involving cross-border trade, representing a greater complexity for the value chain.
…economic operators, often involving cross-border trade, representing a greater complexity for the value chain. Therefore, an exemption from the 40% reuse requirement for transport packaging would substantially reduce the administrative and operational burden currently facing the industry. In conclusion, IMA-Europe values the Commission’s efforts to adapt the regulatory framework to industrial realities, ensuring that sustainability targets do not compromise transport safety or the competitiveness of European industry. Ref.
…that sustainability targets do not compromise transport safety or the competitiveness of European industry. Ref. Ares(2026)227570 - 09/01/2026 Industrial Minerals Association Europe Rue des Deux Eglises 26, Box 2, BE-1000 Brussels, Belgium Transparency registry number: 14190001484-01 Contact us: [email protected];www.ima-europe.eu IMA-Europe is an umbrella organisation which brings together several European associations specific to individual minerals such as: Andalusite, Attapulgite, Calcium Carbonate, Bentonite, Borates, Diatomite, Dolomite, Feldspar, Kaolin, Lime, Mica, Plastic Clays, Sepiolite, Silica, Magnesite and Talc. Together, IMA-Europe's associations represent over 250 companies in 28 countries and produces raw materials essential for our modern life.