Finnish Forest Industries Federation (Metsäteollisuus ry)

…1 (6) 8 February 2023 FINNISH FOREST INDUSTRIES FEDERATION, SNELLMANINKATU 13, 00170 HELSINKI, TEL. +358 9 132 61, WWW.FORESTINDUSTRIES.FI Finnish Forest Industries Federation's position on the EU Commission's Packaging and Packaging Waste Regulation proposal The Finnish Forest Industries Federation (FFIF) is made up of 71 member companies that operate in the pulp, paper, paperboard, and packaging industries as well as in the wood products industry. The Federation represents Finland’s entire pulp, paper, and paperboard industry as well as about 65% of the wood products industry and is a member Confederation of European of Paper Industries (Cepi). The forest industry has a significant role in Finland by employing 42,000 people directly and twice as much when indirect jobs are included.

…significant role in Finland by employing 42,000 people directly and twice as much when indirect jobs are included. FFIF supports the European Commission’s objective in Packaging and Packaging Waste Regulation (PPWR) proposal to reduce packaging waste and increase the reuse, recyclability, and recycling of packaging materials. It is important that recyclability and re-use of packaging are seen as complementary solutions and that the operators have the possibility to choose the best packaging solution from environmental, end-use and context point of view. It is positive that the recyclability of packaging is approached through the "design for recycling" guidelines. At the same time, it is crucial to ensure that the PPWR and the products placed on the market contribute to the EU Green Deal targets.

…it is crucial to ensure that the PPWR and the products placed on the market contribute to the EU Green Deal targets. We believe that some improvements are needed to prevent unintended consequences on the environment. General views regarding the PPWR proposal • Recyclable single-use and reusable packaging should be complementary solutions to achieve sustainability. So far, the EU's waste legislation has been guided by the basic principle that the generation of waste should be avoided. The next best option is re-use, then recycling, then utilization as energy and finally landfill. However, it is possible to deviate from the hierarchy if it is possible to demonstrate e.g., in a life cycle assessment that other options (than reusable packaging) deliver better environmental results. Also, according to EU's circular economy action plan, all packaging should be either reusable or recyclable by

…results. Also, according to EU's circular economy action plan, all packaging should be either reusable or recyclable by 2030. • The proposed regulatory change to strongly focus on re-use creates uncertainty and compromises the success of past and ongoing investments in recycling technology. For the past decade, legislation has encouraged industry to develop recycling infrastructure and recyclable packaging. Industry has invested more and more in new technologies and achieved very high (> 80%) recycling rate of paper and cardboard packaging in the EU. The key to achieve even higher recycling rates would be to develop and harmonize the waste collection infrastructure so that in all EU countries packaging is collected separately per material (plastic, paper & cardboard, glass, and metal packaging as their own fractions).

…is collected separately per material (plastic, paper & cardboard, glass, and metal packaging as their own fractions). If all packaging waste is mixed, it will negatively affect the quality and yield of recycled fibre from paper and cardboard packaging. Ref. Ares(2023)2799707 - 20/04/2023 2 (6) 8 February 2023 • Climate goals, EU climate legislation and the sustainable carbon cycle policy framework guide industry to reduce the use of fossil raw materials. The goal of the PPWR proposal to increase reusable packaging means in practice favouring plastic packaging in transport, food and drink, and HORECA sectors. Hence, re- use can have the undesired affect to increase the use of finite fossil feedstock for packaging, which goes against the EU climate goals. Therefore, we would like to highlight these key challenges, and propose the following changes:

…the EU climate goals. Therefore, we would like to highlight these key challenges, and propose the following changes: 1. Overly prescriptive re-use goals for different packaging solutions (Article 26): Recyclable single-use and reusable packaging should be complementary solutions to achieve the best environmental performance, and when recyclability, recycling and collection targets are met, fibre-based s packaging should be exempted from the re-use targets in article 26. This approach would be in line with the waste hierarchy as defined in the Waste Framework Directive (WFD).

…article 26. This approach would be in line with the waste hierarchy as defined in the Waste Framework Directive (WFD). 2. Ban on certain types of packaging (Article 22): Instead of bans, the regulation should guide the future development towards improving the recycling and mandatory collection of single-use packaging in member states, and if recyclability, recycling and collection targets are met, fibre-based packaging should be exempted from the banned packaging in article 22 in line with the WFD. 3. Mandatory recycled content usage in plastic packaging (Article 7): The requirement should be limited to packaging consisting predominantly of plastics and exclude plastic parts. When calculating the share of recycled plastic, bio-based plastic should be equated with recycled plastic.

…parts. When calculating the share of recycled plastic, bio-based plastic should be equated with recycled plastic. 4. Industry participation in the preparation of delegated acts regarding recyclability and recycling at scale (Article 6): It is crucial to find a cooperative method, which would guarantee the strong participation of the industry in the preparation of the delegated regulations. CEN should be commissioned to work on standards related to recyclability and recycling at scale. 3 (6) 8 February 2023 Key challenges in the PPWR proposal in more detail 1. Over-ambitious and very detailed re-use goals for different packaging solutions (Article 26) • Take away beverage and food packaging would be replaced by reusable packaging in the future (up to 40/80% by 2040). • Very high re-use targets for e-commerce packaging and transport packaging (50% by 2040).

(up to 40/80% by 2040). • Very high re-use targets for e-commerce packaging and transport packaging (50% by 2040). • Intra and inter industry transport packaging must be 100% reusable FFIF's position: Re-use should be increased where it is best from an environmental point of view. However, unjustified, too detailed, and binding re- use targets may favour an uptake of non-renewable fossil-based materials which can prove more difficult to recycle. Reusability may often imply the use of thicker, heavier, and washable materials mostly obtained from fossil sources. Reusability targets should be set after considering the environmental impact of raw materials extractions, use phase and end of life management. Often recyclability represents a better solution than re-use, and where that is the case, it should remain the preferred product design characteristic.

…better solution than re-use, and where that is the case, it should remain the preferred product design characteristic. Economic operators shall hence be exempted from the obligation to meet the targets in Article 26 provided that 1) the packaging types used (defined in Annex II) have reached 90 % recycling rate 2) Are recyclable according to paragraph 2 of Article 6. Additionally, in line with the article 26 paragraph 17, the Commission must review the 2040 re-use targets after taking stock of the status of 2030 re-use targets. When doing so, it will have to assess the fitness and feasibility of the current 2040 objectives in consideration of the scientific and technical development in material and product design, environmental benefits achieved, effectiveness of the reuse infrastructures and systems as well as material recycling performance.

…benefits achieved, effectiveness of the reuse infrastructures and systems as well as material recycling performance. Before reusable packaging is categorically preferred for different uses, it should be clear that its overall environmental impact in actual use is lower than the impact of single-use alternatives. In addition to environmental impacts, the effects should be evaluated in terms of hygiene, food health and safety. The proposal lacks a clear framework and rationale for the expansion of re-use systems, including information and evidence on the impact of existing systems. For example, knowing how many re-use cycles need to be performed to compensate for externalities such as the increased amount of material required (reusable packaging is larger and heavier), transportation, washing/cleaning/ disinfecting, inspecting, and refurbishing would be important.

…larger and heavier), transportation, washing/cleaning/ disinfecting, inspecting, and refurbishing would be important. Reusable packaging is often thick-walled, which means that their production requires more raw materials than disposable packaging. Reusable packaging should also be recyclable when it reaches its end of life (in accordance with Article 6). There is no 'one size fits all' type solution. The transition to a circular economy requires a systemic perspective. The economic operator should have the freedom to choose the best possible recyclable or reusable packaging solution in terms of functionality and environmental impact during the entire life cycle on a case-by-case basis. This is not possible if legislation demands the use of reusable packaging in all applications.

24 → 12

originalus šaltinis (PDF) ↗

…1 (3) 22 December 2025 FINNISH FOREST INDUSTRIES FEDERATION, SNELLMANINKATU 13, FI-00170 HELSINKI, TEL. +358 9 132 61, WWW.FORESTINDUSTRIES.FI Finnish Forest Industries feedback on the draft Delegated Decision exempting pallet wrappings and straps from 100% reuse requirements We welcome the European Commission services’ draft Delegated Decision as a pragmatic step to ensure that the reuse framework under Regulation (EU) 2025/40 (PPWR) is implemented without undermining transport safety, operational continuity, and the competitiveness of European supply chains. The draft appropriately recognises that mandating the exclusive use of reusable pallet wrappings and straps in all cases captured by PPWR Article 29(2) and (3) risks disproportionate adaptation costs, insufficiently mature automated solutions, and supply chain disruption.

(3) risks disproportionate adaptation costs, insufficiently mature automated solutions, and supply chain disruption. However, the draft leaves unresolved a central risk: pallet wrappings/films and straps remain within scope of the Article 29(1) “in total” 40% reuse target for transport packaging formats, which can create structural unfairness for operators whose transport packaging is predominantly stabilisation/protection formats. This can disproportionately disadvantage SMEs and sectors with complex logistics (including high-volume industrial supply chains), even though the draft itself documents that the shift to reusable wraps/straps entails high costs and complexity.

…even though the draft itself documents that the shift to reusable wraps/straps entails high costs and complexity. The remaining problem: Article 29(1) still captures wraps/films and straps While the draft removes the 100% obligation in Article 29(2) and (3), it explicitly acknowledges that pallet wrappings and straps remain covered by Article 29(1), which establishes the overall 40% reuse target “in total.” As currently proposed, the exemption would not relieve companies from meeting the 40% reuse target specified in Article 29(1). This target requires companies to allocate reuse obligations across various packaging types, including pallets, foldable plastic boxes, boxes, trays, plastic crates, intermediate bulk containers, pails, drums and canisters of any size or material, as well as flexible formats such as pallet wrappings and straps.

…pails, drums and canisters of any size or material, as well as flexible formats such as pallet wrappings and straps. In many cases within our industry, most of the transport packaging consists primarily of pallet wrappings/films, straps. The remaining reuse target 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. Economic operators or sectors whose transport packaging is predominantly stabilisation/protection formats 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).

…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 draft’s own cost and complexity rationale applies not only to the “exclusive use” scenario (100%), but also to any requirement that forces meaningful uptake of reusable wrap/strap systems where they Ref. Ares(2025)11499958 - 22/12/2025 2 (3) 22 December 2025 are not operationally mature. The draft documents substantial costs associated with equipment changes, IT systems, training, and, in some cases, maintaining dual packaging line operations.

…with equipment changes, IT systems, training, and, in some cases, maintaining dual packaging line operations. SMEs and smaller operators, often with limited capex capacity and lower leverage over logistics partners, are at higher risk of being disadvantaged by a reuse target that effectively compels them to adopt costly and complex stabilisation formats or to compensate through other packaging changes that are not feasible in their operations. In modern European supply chains, palletised shipments routinely move through multi-actor networks (manufacturers, co-packers, 3PLs, cross-docks, retailers), with varying load profiles and performance requirements.

…co-packers, 3PLs, cross-docks, retailers), with varying load profiles and performance requirements. A reuse target that “counts” stabilisation wraps and straps as reusable formats absent EU-wide enabling conditions risks: • creating additional handling steps and delays; • increasing unit-load failure risk if performance trade-offs emerge; and • driving duplication of systems (single-use for some flows, reusable for others), increasing overall complexity and cost. For operators in pulping, wood handling, paper and board production, palletised or unitised loads can be heavy, high-volume, and throughput dependent. Stabilisation and protection formats are typically integrated into automated packaging and dispatch lines and are central to: • warehouse productivity (wrapping/strapping cycle times); • damage prevention and claims reduction; and • safe multimodal transport.

(wrapping/strapping cycle times); • damage prevention and claims reduction; and • safe multimodal transport. Proposed amendment to the draft Delegated Decision In this context, we propose the following amendment to the draft Delegated Decision to ensure legal clarity and meaningful relief for economic operators: Amendment Draft 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.

…requirements of these packaging formats established in Article 29(1), 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(2) and (3) of Regulation (EU) 2025/40. 3 (3) 22 December 2025 The draft Delegated Decision is a necessary corrective to ensure feasible PPWR implementation and should be adopted without delay.

Decision is a necessary corrective to ensure feasible PPWR implementation and should be adopted without delay. To avoid unintended market distortion and disproportionate burdens, particularly for SMEs and sectors that rely structurally on stabilisation/protection formats, we recommend extending the policy logic to ensure that pallet wrappings/films and straps used solely for stabilisation and protection are treated consistently and excluded, on a material-agnostic basis, from the Article 29(1) reuse calculation. This approach supports Europe’s circular economy ambitions while safeguarding a cost-competitive and safe supply chain.

originalus šaltinis (PDF) ↗