ACIBEV · Trade and business associations · PT
ACIBEV contribution to the European Commission consultation on the delegated act to establish exemptions from the PPWR’s reuse obligations for plastic wrappings and straps 8th January 2026 ACIBEV - Portuguese Wine and Spirits Association is a non-profit business association established in January 1975, which represents a significant part of the sector's turnover - production, distribution and trade of wines and spirits as well as vinegar and distillation of wine products. Its Associates have an annual turnover of more than 814 million euros, 60% of which are generated through export. Among our Associates are the majority of national export companies, leading companies in the various demarcated regions and companies that create brands that add value to Portuguese wines.
…companies in the various demarcated regions and companies that create brands that add value to Portuguese wines. The key focus of ACIBEV is to assure an open business environment that allows the sustainable development of a legitimate and responsible business. ACIBEV welcomes the opportunity to provide feedback on the European Commission consultation related to the draft delegated act to establish exemptions from the Packaging and Packaging Waste Regulation, PPWR, reuse obligations for plastic wrappings and straps. While the wine sector broadly supports the EU’s objectives included in the PPWR the reuse requirements for transport packaging represents a major concern for the wine sector and its SMEs, which make up the vast majority of the European wine sector.
…a major concern for the wine sector and its SMEs, which make up the vast majority of the European wine sector. ACIBEV welcomes the elements of flexibility introduced in the Commission’s draft delegated act regarding Articles 29(2) and 29(3) on reuse targets for transport packaging (pallet wrapping and straps) as a positive first step. This approach recognises the lack of viable alternatives for glass containers, the potential risk of supply chain disruption, and the disproportionate costs involved.
…for glass containers, the potential risk of supply chain disruption, and the disproportionate costs involved. However, ACIBEV urges decision-makers to introduce additional flexibility under Article 29(1), allowing the exemption of plastic wrapping and straps used in transport packaging from reuse targets, based on the following arguments: KEY ELEMENTS • Safety issue: Transport packaging materials such as stretch wrap and plastic strapping should be regarded as transport safety and load-stabilization tools rather than conventional packaging. Their primary function is to secure bottled goods during handling and transport, preventing pallet instability or collapse, reducing workplace accidents, and avoiding product damage. Wine bottles Ref.
…preventing pallet instability or collapse, reducing workplace accidents, and avoiding product damage. Wine bottles Ref. Ares(2026)185441 - 08/01/2026 are fragile and high value; compromised or previously used stretch wrap/strapping may lose elasticity or tensile strength, increasing the risk of pallet collapse or bottle breakage. Ensuring consistent load stability is critical for preventing costly product loss and workplace injuries; reused packaging cannot reliably guarantee this. There is a significant risk of potential disruption of the supply chain. • No viable alternatives: Plastic wrap and strapping provide high strength, elasticity, and shock absorption using minimal material. Alternative materials (metal, paper, fiber) require more resources, generate higher emissions, and often have lower recyclability.
…materials (metal, paper, fiber) require more resources, generate higher emissions, and often have lower recyclability. • Hygiene and contamination risks: Reusing transport packaging in the wine sector could compromise hygiene, as residues from wine, cork, or other materials may contaminate reused films or strapping. Stretch wrap and strapping often come into contact with pallets that may carry dust, moisture, or residues; repeated reuse could pose contamination risks, particularly for bottles of wine where quality and safety standards are strict. • Environmental impact: Plastic solutions are compatible with circular economy principles and are well suited to industrial recycling streams, achieving high recycling rates. • Waste reduction: Less effective load stabilization increases product damage and waste, resulting in a higher overall environmental impact.
…effective load stabilization increases product damage and waste, resulting in a higher overall environmental impact. • Compatibility with automated logistics: Modern wine logistics rely on automated pallet handling and stretch-wrapping machines designed for single-use films. Reusing packaging can cause machine jams, poor sealing, or uneven wrapping, which could damage bottles. Consistent film quality and tension are essential, and reused stretch wrap may not perform reliably. • Safety of workers: Handling and reusing used strapping or stretch film increases the risk of cuts, abrasions, or other injuries. In the wine sector, where pallets are often tall and heavy, safety is critical. • Economic and logistical impracticality: Collecting, cleaning, storing, and redistributing used stretch wrap or strapping would require significant infrastructure and handling costs.
…storing, and redistributing used stretch wrap or strapping would require significant infrastructure and handling costs. For wine exporters and distributors, the cost and complexity outweigh the environmental gains.