Fibre Packaging Europe

Position of Fibre Packaging Europe on the proposal for a Packaging and Packaging Waste Regulation (PPWR) Fibre Packaging Europe (FPE) is an informal coalition of seven trade associations representing industries involved in forestry, pulp, cardboard (paper, board and carton packaging) production and recycling in Europe, coming together to speak with one voice on the policy issues central to the fibre-packaging value chain in the EU. The fibre-based packaging sector acknowledges the European Commission’s proposal for a Packaging and Packaging Waste Regulation, and looks forward to supporting an evidence-based regulatory approach during the next stages of the legislative process. Both recyclable and reusable items have a role in the transition to a circular economy.

…of the legislative process. Both recyclable and reusable items have a role in the transition to a circular economy. Fibre-based recyclable packaging is produced from low-carbon renewable materials sourced from sustainably managed European forests and recycled at end-of-life. Thanks to sustainable forest management, Europe can proudly claim that it currently has more forest resources than it did a century ago, with the forest area in Europe growing by 19.3 million hectares over the last 30 years.1 In fact, it is estimated that forests and the forest-based sector absorb around 20% of the EU’s total greenhouse gas emissions per year, contributing to the EU’s climate goals.2 Moreover, fibre-based packaging has a high recycling rate (81.6%)3 and is consequently already a key contributor to the circular economy.

…packaging has a high recycling rate (81.6%)3 and is consequently already a key contributor to the circular economy. 1) The industry should be involved in the drafting of the Design for Recycling Guidelines (DfR) in a systematic and transparent way through CEN FPE welcomes the proposed, actionable and forward-looking, definition of recyclability applicable to all packaging. However, the recyclability of the packaging must be assessed while taking into account material specificities via Design for Recycling (DfR) guidelines which provide technically sound guidance for recycling. The DfR should be based on expert judgment and consultation with targeted stakeholders, including recyclers, waste management operators, and technology providers.

…and consultation with targeted stakeholders, including recyclers, waste management operators, and technology providers. Thus, policymakers should ensure that stakeholders from the industry are consulted in a transparent and systemic manner in the drafting process of DfR guidelines. The paper and board recycling, manufacturing and converting industry, which has already invested into and developed recyclability guidelines4, has the knowledge and the expertise to support the development of DfR guidelines which will ensure recyclability by considering the packaging composition, functionality and suitability for recycling in existing streams and with existing technologies.

…packaging composition, functionality and suitability for recycling in existing streams and with existing technologies. A process within the independent standardisation body, European Committee for Standardisation (CEN), would allow for open cooperation and exchange of expertise to set ambitious and realistic requirements on packaging recyclability.

…for open cooperation and exchange of expertise to set ambitious and realistic requirements on packaging recyclability. 2) A mandatory 90% collection target for all packaging formats by 2030 is necessary to reach the recycled at scale obligation in 2035, further increase recycling rates and enhance the quality of the secondary raw materials 4 Paper-Based Packaging Recyclability Guidelines (Cepi, CITPA, ACE, FEFCO, 2019); Circularity by Design Guideline for Fibre-Based Packaging (4evergreen.eu, 2022) , FEFCO-Recyclability-Guidelines Final.pdf 3 Recycling rate of packaging waste by type of packaging, EU27, 2 Climate effects of the forest-based sector in the European Union, Peter Holmgren, FutureVistas AB (2020) 1 The State of Europe's Forests, Forest Europe (2020) ____________________________ About Fibre Packaging Europe Fibre Packaging Europe is an informal coalition of seven trade…

…industries involved in forestry, pulp, paper, board, carton packaging production and recycling from across Europe. Our joint mission is to provide renewable, circular and sustainable fibre-based packaging solutions to European citizens to achieve the European Green Deal objectives. For more information, please contact [email protected] CEPI ECMA EPPA FEFCO PRO CARTON CEPI EUROKRAFT Alliance for Beverage Cartons and the Environment Ref. Ares(2023)2595343 - 12/04/2023 The industry needs enabling conditions to ensure that packaging is recycled at scale by 2035. The first step to recycling is collection. It would be unjustified to ban packaging, as provided for in Art.

…by 2035. The first step to recycling is collection. It would be unjustified to ban packaging, as provided for in Art. 6 (2) (e) of the PPWR, if not recycled at scale in 2035 while the responsibility for collection does not rest with the industry. Such an obligation will penalise the industry, which has no control over the waste collection schemes available in each Member State. Therefore, FPE calls for setting a mandatory 90% collection target for all packaging formats by

…in each Member State. Therefore, FPE calls for setting a mandatory 90% collection target for all packaging formats by 2030. EU-wide minimum requirements and a target for separate waste collection at 90% are necessary to further increase recycling and enhance the quality of the secondary raw materials. To achieve this, separate collection must be easy for consumers. From an operational point of view, FPE supports the principle that waste collection should rely on locally fit and efficient methodologies (e.g., kerbside collection rounds from households and businesses, acceptance in waste centres, etc.). In light of the above, used fibre-based packaging could be collected either in a single paper and board packaging stream or in a paper stream including graphic paper. Beverage cartons could be collected in a separate lightweight stream or as part of a deposit refund system (where this…

…refund system (where this would help reach high collection targets). human health and liability possible implications. 3) Recycling and reuse are complementary to create a circular economy. Policy decisions (including reuse targets) should be evidence-based. 4) FPE recognises that recyclable and reusable options are complementary towards a common goal of achieving a circular economy in the EU. Policy decisions (including reuse targets) should be founded on an evidence-based evaluation of the life-cycle impact of packaging, and its system, accompanied by the evaluation of the economic and technological implications, and consequences for human health and food security.

…by the evaluation of the economic and technological implications, and consequences for human health and food security. Importantly, fibre-based packaging has a critical function in protecting and preserving goods throughout the value chain, extending food lifespan5, and preventing product and food waste6 which contributes to resource efficiency7. Crucially, it safeguards consumer safety in logistics and on the shelf. In addition, it provides nutritional information and tells consumers how to store and prepare food safely. Paper-based products, particularly, contribute to expanding the shelf-life period of products often from hours to many days. 8Furthermore, packaging maintains the quality of sensitive products, such as milk and juices, which provide consumers with essential vitamins and nutrients.

…quality of sensitive products, such as milk and juices, which provide consumers with essential vitamins and nutrients. In some sectors (e.g., in food service systems or logistic systems) recyclable fibre packaging has a better environmental performance than reusable options9. As an example, according to the results of an in-depth and certified LCA study10 conducted by Ramboll, the reusable system in quick service restaurants generates 2.8 times more CO2-equivalent emissions, leads to 3.4 times more fossil resource depletion, consumes 3.4 times more freshwater and generates 2.2 times more fine particles compared to the fibre-based single-use system, thus, further accelerates climate change.

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originalus šaltinis (PDF) ↗

Fibre Packaging Europe Position on the draft Delegated Act establishing exemptions from the PPWR’s reuse obligations for wrappings and straps Fibre Packaging Europe (FPE), a coalition comprising seven trade associations spanning the fibre packaging value chain in Europe, values the predictability created by the Packaging and Packaging Waste Regulation (PPWR), which entered into force on 11 February 2025. FPE, represe nting 1,500 companies with 2,200 industrial facilities across Europe, appreciates the stability of the regulatory framework to facilitate informed decision -making and advance our continent’s transition towards a circular economy. Our sector has already undertaken significant investments to ensure timely compliance with PPWR obligations, reflecting our strong support for the legislation’s objective.

…to ensure timely compliance with PPWR obligations, reflecting our strong support for the legislation’s objective. While we welcome the aim of the draft Delegated Act, which seeks to establish partia l exemptions from the PPWR’s reuse obligations for wrappings and straps, the current proposal does not fully account for the operational impracticality of reuse for straps and wrappings. Reuse targets on wrappings and straps – economically and technically unfeasible In our understanding, Article 1 of the draft Delegated Act introduces exemptions from the obligations set out in Article 29, paragraphs 2 and 3 of the PPWR, while leaving unchanged the requirements under Article 29, paragraph 1, which establishes a 40% reu se target by 2030 for pallet wrappings and straps for stabilisation and protection of products put on pallets during transport.

…by 2030 for pallet wrappings and straps for stabilisation and protection of products put on pallets during transport. In our view, applying a 40% reuse target to pallet stabilisation wrappings, films, and straps is disproportionate and fails to r eflect the essential role these components play in ensuring product integrity and transport safety. As recognised in the draft Delegated Act, automated solutions for reusable packaging are not sufficiently developed yet. Imposing reuse targets on pallet wrappings and straps would disproportionately disadvantage operators and in particular SMEs and operat ors with limited capacity to redesign packaging lines, implement pooling systems and deploy tracking infrastructure.

…limited capacity to redesign packaging lines, implement pooling systems and deploy tracking infrastructure. Furthermore, for companies importing goods from non -EU countries or geographically remote locations, reuse obligations would impose substa ntial costs and operational challenges (e.g., in view of the need to send back the pallet wrappings and straps). The feasibility of returning packaging is extremely limited, and implementing such changes would require a complete overhaul of logistics syste ms, including reverse flows and servicing for new stabilisation components. Furthermore, while Article 1 of the draft Delegated Act introduces flexibility, it does not address the reuse targets set out in Article 29, paragraph 1 of the PPWR. This provision fails to reflect real -world operational conditions. Indeed, in proportion, straps and Ref.

…of the PPWR. This provision fails to reflect real -world operational conditions. Indeed, in proportion, straps and Ref. Ares(2026)216258 - 09/01/2026 wrappings represent a very high share of the packaging units operators must use during their daily operations, making compliance with a 40% reuse ratio for these formats virtually impossible in practice. Exemption applicable to all materials FPE supports an exemption for all materials as proposed in this draft. The selection of pallet wrapping solutions exempt from reuse targets must remain dependent on logistical, environmental, and transport conditions. A professional responsible for product safety and hygiene is best placed to determine the most appropriate materials.

A professional responsible for product safety and hygiene is best placed to determine the most appropriate materials. An approach applicable to all materials ensures EU reuse objectives are balanced with operational realities while supporting ongoing efforts to improve recyclability and reduce plastic consumption. Proposed amendment Therefore, we propose the following amendment to Article 1 of the draft Delegated Act: “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), Article 29(2) and (3) of Regulation (EU) 2025/40.” A comprehensive exemption for pallet wrappings and straps represents the most effective and pragmatic policy choice.

…comprehensive exemption for pallet wrappings and straps represents the most effective and pragmatic policy choice. It safeguards product integrity, hygiene, and worker safety while maintaining cost -competitive supply chains across Europe. This approach a ligns with the overarching goals of the PPWR without disproportionate burdens on economic operators. __________________________ About Fibre Packaging Europe Fibre Packaging Europe is an informal packaging coalition of seven trade associations representing industries involved in forestry, pulp, paper, board and carton production and recycling from across Europe. Our joint mission is to provide renewable, circular and sustainable fibre-based packaging solutions to European citizens to achieve the European Green Deal objectives. For more information, please contact [email protected]

originalus šaltinis (PDF) ↗