Interesų grupė
Statement on the proposal for exemptions for pallet wrappings and straps from the reuse requirements in the EU Regulation on packaging and packaging waste (2025/40 – PPWR) On 10 December 2025, the EU Commission proposed a delegated act under Article 29(18) PPWR, which exempts economic operators who use pallet wrappings and straps in the cases referred to in Article 29(2) and (3) PPWR from the 100% reuse requirements from 2030 onwards. The proposal follows on from a corresponding announcement by the Commission in April 2024. The initiative was prompted by editorial changes to the provisions of Article 29 PPWR at the end of the brief legislative process, which – presumably unintentionally – had drastically extended the 100% reuse requirements in Article 29(2) and (3) PPWR, and thus the ban on single-use solutions.
…extended the 100% reuse requirements in Article 29(2) and (3) PPWR, and thus the ban on single-use solutions. We believe it is right for the Commission to make use of the option provided for in Article 29(18) PPWR to correct the reuse requirements where they are neither ecologically nor economically sensible. This applies in particular to the 100% quotas in Article 29(2) (for transports between different sites of a company or affiliated companies within the EU) and Article 29(3) (for transport between independent companies within the same EU Member State), but also to the 40% quota in total for the 12 packaging formats mentioned there in the remaining cases (Article 29(1)). As provided for in Article 29(18) PPWR, the Commission should not only take economic considerations into account, but also aspects relating to hygiene and food safety and in particular environmental issues (see 1.
…into account, but also aspects relating to hygiene and food safety and in particular environmental issues (see 1. below). This is particularly important in light of the announcement by the Commission in its proposal for an Environmental Omnibus that it will examine further exemptions ("additional flexibilities") from the reuse requirements of Art. 29 for other packaging formats (see Communication of 10 December 2025, COM(2025) 980 final). In this context, we also consider it necessary to clarify the system of Article 29(1-3) PPWR (see 2. below). Finally, economic studies have shown that the costs of banning single-use pallet wrappings and straps are much higher than the Commission assumes in its proposal. The impact assessment should therefore be corrected (see 3. below). We comment on the proposal as follows: 1.
…proposal. The impact assessment should therefore be corrected (see 3. below). We comment on the proposal as follows: 1. General exemption for pallet wrapping and strap required The proposal is a step in the right direction, but it does not go far enough: instead of exempting economic operators from the 100% reuse obligation in the cases referred to in Article 29(2) and (3) PPWR, the Commission should rather exempt pallet wrapping and straps as such from all reuse requirements. The basis for this is provided by Article 29(18)(c) PPWR and the life cycle assessments that have since been submitted. Ref. Ares(2026)131260 - 07/01/2026 2 The limitation of the exemption in the Commission proposal to Article 29(2) and (3) PPWR is untenable in view of the scientific findings obtained in the meantime in the studies by ifeu, RCD, Fraunhofer IMWS, GVM and JRC/Deloitte.
…of the scientific findings obtained in the meantime in the studies by ifeu, RCD, Fraunhofer IMWS, GVM and JRC/Deloitte. Overall, the studies show that the reasons justifying an exemption from paragraphs 2 and 3 (costs, ecological misdirection, technical impossibility, safety risks) apply equally to the circumstances of Article 29(1) PPWR. Maintaining the obligation under paragraph 1 for users of pallet wrapping and strap therefore violates the principle of proportionality (Article 5(4) TEU) and the principle of objective impossibility. This also follows from the application of the waste hierarchy pursuant to Article 4(2) of the EU Waste Framework Directive (2008/98), according to which priority is given to the measure that ‘deliver the best overall environmental outcome. The application of Art.
…to which priority is given to the measure that ‘deliver the best overall environmental outcome. The application of Art. 29(1) PPWR to pallet wrapping and straps would force companies in the EU to make high investments in systems that are ecologically disadvantageous, technically unsafe and pose occupational safety risks due to manual handling instead of automation. However, high-wage countries are dependent on extensive automation, particularly of packaging processes, in order to remain competitive. a) Reducing costs to remain competitive The current Commission proposal would mean that the quota under Article 29(1) PPWR would continue to apply to pallet wrapping and straps. Pallet wrapping and straps would be part of the 40% reuse quota and would therefore have to be included in the calculation of the average reusable packaging.
…of the 40% reuse quota and would therefore have to be included in the calculation of the average reusable packaging. This would result in a significant cost burden for companies and weaken their competitiveness, especially in comparison to non-EU competitors. A practical example: Pallets (100% reuse under optimal circumstances) are usually filled with goods (e.g. cardboard boxes, which are exempted from reuse, Art. 29(4)(d)) and then secured with pallet wrapping and straps (0% reuse in each case). If the average is calculated in accordance with Art. 29(1) and Art. 30(1) PPWR, pallets, pallet wrapping and straps in this optimal example only achieve an average reuse rate of 33% each and therefore do not meet the requirements of Art. 29(1) PPWR.
…example only achieve an average reuse rate of 33% each and therefore do not meet the requirements of Art. 29(1) PPWR. Many companies in the manufacturing and logistics sectors primarily use these three packaging formats and cannot compensate for the quota by increasing the reuse of other packaging formats specified in Article 29(1) of the PPWR. In particular, companies that export to countries outside the EU would also have to install two separate packaging lines for pallet securing, single-use for export and reusable for transport within the EU, which would involve considerable costs. Finally, calculating and reporting the respective "number of equivalent [packaging] units" (see Article 30(1) PPWR) for pallet wrapping and strap represents a considerable bureaucratic burden – especially since it is unclear what an "equivalent unit" of pallet wrapping and straps is.
…bureaucratic burden – especially since it is unclear what an "equivalent unit" of pallet wrapping and straps is. The RCD study (April 2025) estimates the cost of switching to reusable systems for pallet securing in the eight economic sectors examined alone at up to €5 billion per year, plus €8.4 billion in investment costs. The study assesses the transition from current single-use pallet wrapping to reusable alternatives based on the specific requirements in eight key sectors: agriculture, dairy, water, glass, cement, construction, retail and plastics – each represented by a specific product. The study focuses on analysing long-term costs, assuming that reusable solutions exist, but also discusses the short to medium-term (15 years) transition costs in qualitative terms.
…reusable solutions exist, but also discusses the short to medium-term (15 years) transition costs in qualitative terms. 3 A study by GVM Gesellschaft für Verpackungsmarktforschung concludes that switching from single- use straps to reusable alternatives only makes sense in a few highly standardised B2B cycles – where they are already in use. In all other cases, replacing straps would lead to increased safety risks, very high logistical costs and significantly higher expenses. b) Taking environmental aspects into account We also consider it imperative that the Commission take into account existing studies on the environmental impact of a widespread ban on commonly used pallet wrapping and straps in its proposal. Recital 91 PPWR expressly provides for environmental concerns to be taken into account throughout the entire life cycle of packaging when implementing the reuse requirements.
…to be taken into account throughout the entire life cycle of packaging when implementing the reuse requirements. Since April 2025, the Commission has had access to a comparative life cycle analysis prepared by the Institute for Energy and Environmental Research (ifeu) based on a robust life cycle analysis methodology in accordance with ISO 14040 and 14044 standards and critically reviewed by a panel of four experts. The study shows that, for all areas of application examined, single-use pallet wrapping has advantages over reusable packaging in all analysed environmental impact categories if the proportion of post-consumer recycled material (PCR) is at least 35%, which will be the case in 2030 due to Article 7(1)(d) PPWR. The study delivers a clear message: reuse is not the more sustainable option for pallet wrapping.
Article 7(1)(d) PPWR. The study delivers a clear message: reuse is not the more sustainable option for pallet wrapping. The study therefore recommends that this packaging format be exempted from all reuse requirements of Article 29 (1-3) of the PPWR. c) Consider technical feasibility A legal obligation must not require anything impossible or unreasonable from the addressee of the standard (impossibilium nulla obligatio est). Existing studies show that reusing pallet wrappings and straps in accordance with the quota in Article 29(1) PPWR is technically impossible and also jeopardises traffic safety. Pallet wraps in the form of stretch or wrapping film are wound spirally around the load unit. The film is stretched to its maximum extent mechanically, causing it to contract after application and secure the packages.
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…1 Joint Statement of the Plastics Packaging Industry in France and Germany on the Circular Economy Action Plan by the European Commission, 11 March 2020 Content Introduction: Towards a Circular Economy ............................................................................ 3 General requirements of the legal framework in order to achieve a more circular economy .. 4 The circular economy must remain a market economy ................................................... 4 Safeguard the single market ........................................................................................... 4 Focus on harmonized and reliable framework conditions and implementation of existing law .................................................................................................................................
........................................................................................................................ 5 Conduct thorough impact assessment ............................................................................ 5 Summary of main recommendations ..................................................................................... 6 Revision of the Essential Requirements ......................................................................... 6 Mandatory requirements for recycled content for plastic packaging ................................ 6 Own resource based on the amount of non-recycled plastic packaging waste (“Plastics Tax”) ...............................................................................................................................
........................................................................................................................ 7 Detailed Recommendations................................................................................................... 8
Recommendations................................................................................................... 8 1. Review of the Essential Requirements for packaging ........................................................ 8 Reducing (over)packaging and packaging waste............................................................ 8 Design for re-use and recyclability of packaging ............................................................. 9 Packaging restrictions ...................................................................................................10 Reducing the complexity of the packaging materials, including number of materials and polymers used ...............................................................................................................11
…used ...............................................................................................................11 2. Mandatory requirements for recycled content for plastic packaging .................................12 Rules for the safe recycling into food contact materials .................................................15 Ref. Ares(2020)7987046 - 29/12/2020 2 Rules on measuring recycled content in products (i.e. PET bottles) ..............................15 3. Addressing the presence of microplastics in the environment ..........................................15 Reducing intentionally added microplastics and tackling pellets ....................................15 Closing the gaps on scientific knowledge related to the risk and occurrence of microplastics in the environment, drinking water and foods ...........................................16
…occurrence of microplastics in the environment, drinking water and foods ...........................................16 4. Own resource based on the amount of non-recycled plastic packaging waste (“Plastics Tax”) ................................................................................................................................16 5.
…5. Further measures of importance to plastics packaging ....................................................17 Harmonise separate collection systems and EU-wide labelling that facilitates the correct separation of packaging waste at source .......................................................................17 Addressing waste exports from the EU ..........................................................................18 Further measures on waste prevention and circularity ...................................................18 Policy framework on bio-based and biodegradable or compostable plastics..................19 Sustainable product policy framework ...........................................................................19 References ...........................................................................................................................21 3 Introduction…
…11 March 2020 the EU Commission published the new Circular Economy Action Plan as announced in the Green Deal. "Packaging" and "Plastics" are two of the seven value chains that the Commission pays particular attention to. Elipso and IK represent the plastic converting industries of France and Germany with together about 400 member companies, mostly SMEs in the field of plastic packaging production. The branch in both countries produces a revenue of 23 bn Euro and employs 130.000 people. The shift towards a Circular Economy is a key challenge for industry and governments as it reduces dependence on fossil raw materials and CO2 emissions. Under the conditions of climate neutrality, which the EU is aiming for the year 2050, high-quality recyclates will have to make a significant contribution to securing the supply of raw materials to the plastics industry.
…will have to make a significant contribution to securing the supply of raw materials to the plastics industry. The amounts of littered plastic waste in the environment have been taken by our companies as a wake-up call. Plastic packaging waste simply does not belong in the environment. That is why we are committed both at home and abroad to ensuring that all plastic packaging waste is collected for recycling or recovery and does not end up in a landfill or - worse - in the environment. Working towards the Commission’s goals requires major efforts from public actors at EU, national and local levels and all parts of the packaging value chain. It requires in particular investments in innovative packaging design, as well as in collection, sorting and recycling technologies and related infrastructures.
…innovative packaging design, as well as in collection, sorting and recycling technologies and related infrastructures. Together, all players involved in the plastics value chain must ensure that plastics can be recycled with the highest possible quality and without material losses. For the plastics packaging industry, this brings great challenges, but also new opportunities. Plastics are needed like no other material in tomorrow’s climate-neutral economy as energy and resource-saving packaging for our goods. The plastics packaging associations in France and Germany, along with many of their member companies, have therefore signed the Circular Plastic Alliance striving towards 10 million tonnes recycled plastics used to make new products in the EU by 2025.
Plastic Alliance striving towards 10 million tonnes recycled plastics used to make new products in the EU by 2025. To achieve this, the French and German producers of plastics packaging actively engage with the value chain partners and invest in research and the development of new plastic packaging. Together, they aim at increasing the proportion of recyclable or reusable household packaging on the market to at least 90% by 2025 and at raising the use of recycled materials in the production of plastic packaging to 1,44 million tonnes. The transition from a linear to a circular and climate-neutral economy requires a profound structural change in the supply of raw materials. This change must now be promoted.
…economy requires a profound structural change in the supply of raw materials. This change must now be promoted. The plastics producing, converting and recycling companies urgently need reliable and harmonized framework conditions and planning security for their investments towards a circular economy. Policy makers are therefore called upon to set the course for structural change by setting clear goals and reliable framework conditions. In view of this, we would like to comment on the new Circular Economy Action Plan by the European Commission.
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…1 Joint Statement of the Plastics Packaging Industry in France and Germany on the Circular Economy Action Plan by the European Commission, 11 March 2020 Content Introduction: Towards a Circular Economy ............................................................................ 3 General requirements of the legal framework in order to achieve a more circular economy .. 4 The circular economy must remain a market economy ................................................... 4 Safeguard the single market ........................................................................................... 4 Focus on harmonized and reliable framework conditions and implementation of existing law .................................................................................................................................
........................................................................................................................ 5 Conduct thorough impact assessment ............................................................................ 5 Summary of main recommendations ..................................................................................... 6 Revision of the Essential Requirements ......................................................................... 6 Mandatory requirements for recycled content for plastic packaging ................................ 6 Own resource based on the amount of non-recycled plastic packaging waste (“Plastics Tax”) ...............................................................................................................................
........................................................................................................................ 7 Detailed Recommendations................................................................................................... 8
Recommendations................................................................................................... 8 1. Review of the Essential Requirements for packaging ........................................................ 8 Reducing (over)packaging and packaging waste............................................................ 8 Design for re-use and recyclability of packaging ............................................................. 9 Packaging restrictions ...................................................................................................10 Reducing the complexity of the packaging materials, including number of materials and polymers used ...............................................................................................................11
…used ...............................................................................................................11 2. Mandatory requirements for recycled content for plastic packaging .................................12 Rules for the safe recycling into food contact materials .................................................15 Ref. Ares(2020)4150459 - 06/08/2020 2 Rules on measuring recycled content in products (i.e. PET bottles) ..............................15 3. Addressing the presence of microplastics in the environment ..........................................15 Reducing intentionally added microplastics and tackling pellets ....................................15 Closing the gaps on scientific knowledge related to the risk and occurrence of microplastics in the environment, drinking water and foods ...........................................16
…occurrence of microplastics in the environment, drinking water and foods ...........................................16 4. Own resource based on the amount of non-recycled plastic packaging waste (“Plastics Tax”) ................................................................................................................................16 5.
…5. Further measures of importance to plastics packaging ....................................................17 Harmonise separate collection systems and EU-wide labelling that facilitates the correct separation of packaging waste at source .......................................................................17 Addressing waste exports from the EU ..........................................................................18 Further measures on waste prevention and circularity ...................................................18 Policy framework on bio-based and biodegradable or compostable plastics..................19 Sustainable product policy framework ...........................................................................19 References ...........................................................................................................................21 3 Introduction…
…11 March 2020 the EU Commission published the new Circular Economy Action Plan as announced in the Green Deal. "Packaging" and "Plastics" are two of the seven value chains that the Commission pays particular attention to. Elipso and IK represent the plastic converting industries of France and Germany with together about 400 member companies, mostly SMEs in the field of plastic packaging production. The branch in both countries produces a revenue of 23 bn Euro and employs 130.000 people. The shift towards a Circular Economy is a key challenge for industry and governments as it reduces dependence on fossil raw materials and CO2 emissions. Under the conditions of climate neutrality, which the EU is aiming for the year 2050, high-quality recyclates will have to make a significant contribution to securing the supply of raw materials to the plastics industry.
…will have to make a significant contribution to securing the supply of raw materials to the plastics industry. The amounts of littered plastic waste in the environment have been taken by our companies as a wake-up call. Plastic packaging waste simply does not belong in the environment. That is why we are committed both at home and abroad to ensuring that all plastic packaging waste is collected for recycling or recovery and does not end up in a landfill or - worse - in the environment. Working towards the Commission’s goals requires major efforts from public actors at EU, national and local levels and all parts of the packaging value chain. It requires in particular investments in innovative packaging design, as well as in collection, sorting and recycling technologies and related infrastructures.
…innovative packaging design, as well as in collection, sorting and recycling technologies and related infrastructures. Together, all players involved in the plastics value chain must ensure that plastics can be recycled with the highest possible quality and without material losses. For the plastics packaging industry, this brings great challenges, but also new opportunities. Plastics are needed like no other material in tomorrow’s climate-neutral economy as energy and resource-saving packaging for our goods. The plastics packaging associations in France and Germany, along with many of their member companies, have therefore signed the Circular Plastic Alliance striving towards 10 million tonnes recycled plastics used to make new products in the EU by 2025.
Plastic Alliance striving towards 10 million tonnes recycled plastics used to make new products in the EU by 2025. To achieve this, the French and German producers of plastics packaging actively engage with the value chain partners and invest in research and the development of new plastic packaging. Together, they aim at increasing the proportion of recyclable or reusable household packaging on the market to at least 90% by 2025 and at raising the use of recycled materials in the production of plastic packaging to 1,44 million tonnes. The transition from a linear to a circular and climate-neutral economy requires a profound structural change in the supply of raw materials. This change must now be promoted.
…economy requires a profound structural change in the supply of raw materials. This change must now be promoted. The plastics producing, converting and recycling companies urgently need reliable and harmonized framework conditions and planning security for their investments towards a circular economy. Policy makers are therefore called upon to set the course for structural change by setting clear goals and reliable framework conditions. In view of this, we would like to comment on the new Circular Economy Action Plan by the European Commission.
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Position of IK Industrievereinigung Kunststoffverpackungen on the proposal by the European Commission for a EU Packaging and Packaging Waste Regulation from 30.11.2022 We comment on the European Commission's proposal for an EU Regulation on packaging and packaging waste (COM(2022)677). The proposal pursues the goal of promoting the transformation to a Circular Economy through harmonised EU-wide sustainability and labelling requirements for packaging as well as minimum requirements for extended producer responsibility, packaging waste collection and recovery. As part of the Green Deal, the legislative proposal is intended to contribute to the overarching goal of climate neutrality for Europe by 2050. The regulation offers an opportunity for the sustainable transformation of the packaging industry.
…for Europe by 2050. The regulation offers an opportunity for the sustainable transformation of the packaging industry. Plastic packaging manufacturers have invested in the recyclability of their products and stand ready with innovative solutions that combine high material efficiency with high recyclability and the use of recycled materials. In order not to jeopardise the sustainable transformation, the regulation should be adopted before the European Parliament elections in 2024. With our recommendations below, we want to contribute to the success of the regulation, especially in economic and ecological terms. The aim of our comments is to create a fair and dynamic market environment that promotes the rational use and an energy-efficient circular economy of packaging materials and prevents ecological misdirection, especially to the detriment of climate protection.
…economy of packaging materials and prevents ecological misdirection, especially to the detriment of climate protection. At the same time, our comments are aimed at the most effective implementation of the regulation by economic actors, enforcement authorities and member states, which is a prerequisite for the law to be applied consistently and to have the intended effects on the environment and market transformation. Summary: A. We welcome the following points in the EU Commission's proposal for an EU Packaging Regulation:
Summary: A. We welcome the following points in the EU Commission's proposal for an EU Packaging Regulation: 1. A regulation protects the internal market and facilitates the transformation: The replacement of the previous Directive 94/62/EC by a Regulation with direct effect facilitates the enforcement of harmonised packaging rules in the EU internal market and protects the free exchange of - mostly packaged - goods from inconsistent national packaging bans, labelling and design requirements. In recent years, national packaging regulations have led to a patchwork of different regulations within the EU. Harmonised packaging regulations are also necessary because only they enable the necessary economies of scale for the economic transformation towards a single EU-wide Circular Economy. The proposed regulation is rightly based on the legal basis of Article 114 TFEU, as was the previous…
…regulations, e.g. on packaging design, labelling or producer responsibility (Chapters II, III and IV of the proposal). 2. Reduction of packaging consumption: We welcome the target to gradually reduce the per capita consumption of packaging waste by 15% by 2040 compared to 2018 (Article 38). The requirement that the weight and volume of packaging should be kept as low as possible, taking into account its functionality (Article 9), and that the permissible empty spaces in grouped, Ref. Ares(2023)885634 - 07/02/2023 2 transport and e-commerce packaging should be limited (Article 21), in accordance with the motto "pack as much as necessary, as little as possible", will contribute to this aim. Due to their low weight and high functionality, plastic packaging have great potential for material-saving and reduction of packaging waste. Through technical innovation, the weight of plastic…
…waste per year. Due to its low weight and stability, plastic packaging is also well suited as reusable packaging. 3. Design-for-recycling of packaging is the prerequisite for quality recycling: Design-for-recycling is a prerequisite for an economical, energy-efficient and quality-oriented packaging recycling and thus for increasing the uptake of recycled materials in packaging and products of the same material. Therefore, it is right to make minimum requirements for recyclability a market prerequisite and to additionally promote the highest possible degree of recyclability financially (Article 6). In order to minimise the quantity and quality losses in recycling and to achieve the most cost- and energy-efficient recycling possible, we propose to increase the recyclability requirements by raising the minimum recoverable content of a packaging from 70 to 80% by weight (see below C. I.2.)…
C. I.2.) and clarifying that only primary raw materials of the same material type should be substituted (see C. I.3.). 4. Better separate collection and deposit systems are needed for high recycling rates: The obligation of member states for the separate collection of all packaging waste contained in Article 43, also in the public space, forms an important prerequisite for achieving the ambitious recycling targets (Article 46), the requirements for the recyclability of packaging ("at scale" criterion, Article 6) and the requirements for the use of recyclates (Article 7). The implementation of this obligation by the member states must therefore be pursued with the highest priority. The introduction of a mandatory deposit for single-use beverage containers (Article 44) is also correct. The mandatory deposit introduced in Germany in 2003 has proven its worth: it effectively reduces…
…and enables a highly efficient material cycle with recovery rates of over 97% of the PET used in beverage bottles. 5. Clear labelling of the intended disposal route: In this context, we also welcome the obligation of a corresponding labelling of packaging and the waste containers intended for them (Articles 11 to 12) in order to significantly reduce misdirected waste by consumers. B. The following proposals give us considerable cause for concern and should be urgently improved: 1. Mandatory recycled content quotas: Chemical processes must recover additional waste fractions that cannot be mechanically recycled (Article 7): Minimum recycled content quotas for plastic packaging are intended to ensure security of demand for recyclates independent of the virgin material price and thus investment security for recycling.
…security of demand for recyclates independent of the virgin material price and thus investment security for recycling. This in itself is welcomed, but the associated considerable risks for the availability of mechanically recycled plastics and the security of supply chains must be taken more into account in order to create planning security for all economic operators and to avoid ecological misdirection. In order to avoid the risk that the availability of mechanically produced recyclates on the market is affected by more energy- intensive chemical recycling processes, it is necessary to ensure that chemical processes recover additional waste fractions that cannot be mechanically recycled in such a way that the recyclates can substitute primary raw materials of the same material.
…be mechanically recycled in such a way that the recyclates can substitute primary raw materials of the same material. We therefore call for exemptions for contact-sensitive packaging and the re-examination of the preconditions 5 years after the entry into force of the regulation (see below C. II.). For all other plastic packaging, we call for an effective safety net that protects against marketing bans due to lack of availability of suitable plastic recyclates and thereby secures important supply chains, for example for food. We also consider the flexibilization of the use of recyclates through mass balances and credit-based methods to be a suitable instrument for balancing out the very different prerequisites of various packaging formats for the use of recyclates without reducing the intended demand impulse for 3 recyclates on the market in total.
…formats for the use of recyclates without reducing the intended demand impulse for 3 recyclates on the market in total. Exemptions from the obligation to use recyclates should not be provided for compostable plastics, but for bio-based plastics.
…from the obligation to use recyclates should not be provided for compostable plastics, but for bio-based plastics. 2. Discrimination against plastics leads to environmental misdirection (Articles 22 and 26): The proposed regulation contains measures that discriminate against packaging made of plastic compared to packaging made of other materials without justification. For example, reuse quotas are only envisaged for certain types of plastic packaging. If this packaging is made of other materials no reuse quotas are to apply. Also, according to the proposal, only certain single-use plastic secondary packaging is to be banned at retail, but not packaging made of other materials, without any justification being given. Instead of the intended reduction of single-use packaging, the loopholes merely cause misdirection towards non-regulated single-use packaging made of other materials. In…
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