Austropapier - Vereinigung der Österreichischen Papierindustrie

Brussels, 22 December 2025 Cepi feedback to Public Consultation – Packaging and Packaging Waste Regulation – draft delegated decision exempting pallet wrappings and straps from the reuse obligation. Cepi fully supports the EU’s objective of becoming the world’s first climate-neutral continent. We share your commitment to ambitious circularity goals and are particularly keen to see the Packaging and Packaging Waste Regulation (PPWR) implemented in a timely and effective manner. We welcome the Commission’s decision to propose a material-agnostic exemption that allows the use of bio-based and recyclable alternatives, rather than limiting the scope of the exemption to fossil-based applications. Nevertheless, it is critical to ensure that the PPWR targets are feasible in practice, while safeguarding transport efficiency and safety and avoiding disruptions to supply chains.

…are feasible in practice, while safeguarding transport efficiency and safety and avoiding disruptions to supply chains. In this context, we believe it is essential that the delegated act fully exempts pallet wrappings and straps from reuse targets. Our focus remains on improving the sustainability performance of existing solutions, while actively exploring and developing more sustainable alternatives. Until reusable options that are scalable, cost-effective, and safe are available, the most pragmatic approach is to optimise and minimise the use of single-use materials that are recyclable and recycled in practice. In many cases within our industry, most of the transport packaging we use consists primarily of pallet wrappings/films, straps.

…cases within our industry, most of the transport packaging we use consists primarily of pallet wrappings/films, straps. Thus the 40% reuse target provided in paragraph 1 of article 29 would disproportionately fall on pallet wrappings/films and straps, which can represent a significant share of a company’s transport packaging and, in practice, necessitate substantial operational changes. Furthermore, allowing the use of paper-based alternatives— which are bio-based and recycled in practice — is essential to achieving the PPWR’s broader objectives of reducing greenhouse gas emissions, phasing out fossil- based packaging, and accelerating the EU’s transition to a circular economy. These materials contribute to a greener future by promoting the use of renewable resources and supporting the European bioeconomy.

…contribute to a greener future by promoting the use of renewable resources and supporting the European bioeconomy. For the above reasons, we deem critical that the Commission considers broadening the scope of the exemption to paragraph 1 of article 29 for pallet wrappings or straps for stabilisation and protection of products put on pallets during transport in addition to paragraphs 2 and 3 and propose the following text amendment: “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), Article 29(2) and (3) of Regulation (EU) 2025/40”. Justification:

…these packaging formats established in Article 29(1), Article 29(2) and (3) of Regulation (EU) 2025/40”. Justification: 1. Lack of viable, scalable alternatives • Reusable wrapping systems (e.g. reusable nets, straps, or rigid containment) are: o Not universally compatible with different pallet sizes, loads, and product types. o Often unsuitable for irregular, fragile, or mixed loads. Ref. Ares(2026)162527 - 08/01/2026 • Many alternatives require closed-loop logistics, which are not feasible for long, cross-border, or multi-actor supply chains. • There is currently no single alternative that matches the flexibility, performance, hygiene, and cost efficiency of single-use wrap across all transport scenarios.

…matches the flexibility, performance, hygiene, and cost efficiency of single-use wrap across all transport scenarios. 2. Safety and liability risks • Load stability is critical for preventing pallet collapse during handling, transport, and storage. Single-use stretch wrap and straps are specifically designed to ensure consistent tension and containment. • Worker safety would be compromised if alternative systems fail or are improperly applied, increasing the risk of accidents and injuries. • Liability exposure would increase for manufacturers, logistics operators, and retailers if damage or injury results from insufficient load securing.

…for manufacturers, logistics operators, and retailers if damage or injury results from insufficient load securing. 3. Hygiene and contamination concerns • Single-use pallet wrap provides a clean, uncontaminated barrier, which is particularly important for: o Food and beverage products o Pharmaceuticals and medical goods • Reusable systems raise cross-contamination risks unless washed, inspected, and certified between uses, creating additional operational burdens and costs.

…risks unless washed, inspected, and certified between uses, creating additional operational burdens and costs. 4. Disproportionate environmental trade-offs • High reuse targets which are close to a ban (70% by 2040) could lead to: o Increased product damage and food waste, which typically has a much higher environmental footprint than the wrapping material itself. o Higher transport emissions if loads must be reconfigured, over-packaged, or transported less efficiently. • Life-cycle assessments often show that minimal material use that prevents product loss delivers a net environmental benefit compared to damage and waste.

…that minimal material use that prevents product loss delivers a net environmental benefit compared to damage and waste. 5. Operational and economic impacts • Logistics operations rely on speed, standardisation, and automation. Single-use wrap integrates seamlessly with automated pallet-wrapping equipment. • Comparative disadvantage on economic operators or sectors whose transport packaging is predominantly stabilisation/protection formats. These economic operators may face a disproportionate compliance burden under the 40% requirement relative to operators whose packaging mix includes higher shares of inherently reusable formats (e.g., intermediate bulk containers). The result is unequal treatment between business models and sectors, particularly where wraps/films and straps are essential to safe transport and efficient automated warehousing. • The cost and complexity do not only apply…

…and exporters would be disproportionately affected, as they lack the scale to implement closed-loop solutions. 6. Cross-border and global supply chain realities • Pallets frequently cross multiple borders and regulatory jurisdictions, making retrieval of reusable wrapping impractical. • In export scenarios, packaging is often not returned, making single-use solutions unavoidable. • A ban in one region could create trade distortions and compliance complexity for international operators. 7. Risk of unintended consequences • Companies may respond by: o Using more secondary or tertiary packaging (e.g. boxes, rigid crates) to compensate for reduced load stability. o Increasing the use of heavier materials, undermining environmental objectives. • Enforcement would be complex, with unclear distinctions between “transport packaging” and “sales packaging.”

…would be complex, with unclear distinctions between “transport packaging” and “sales packaging.” 8. More effective alternatives to high unrealistic reuse target • The regulation already requires that all packaging is recyclable. The new Design-for-recyclability or minimum recycled content requirements for plastic will ensure that pallet wrappings and straps are recyclable and recycled at scale. • Supporting collection and recycling schemes for pallet wrap. Paper-based alternatives are already highly recyclable and recycled. • Allowing exemptions where no technically feasible alternative exists. While reducing unnecessary packaging is a shared objective, replacing single-use pallet wrappings and straps with reusable is not feasible due to safety, hygiene, logistical, and environmental trade-offs, as well as the lack of scalable alternatives for complex and cross-border supply chains. We…

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