The European Federation of Corrugated Board Manufacturers

European Federation of Corrugated Board Manufacturers 250 Avenue Louise, 1050 Brussels, Belgium ⎯ Tel: +32 2 646 40 70 www.fefco.org ⎯ VAT BE 0477 487 844 FEFCO feedback on the European Commission’s upcoming review of the Packaging and Packaging Waste Regulation FEFCO acknowledges the European Commission’s proposal for the Packaging and Packaging Waste Regulation. We support maintain the internal market legal basis and introducing harmonised labelling requirements for packaging across EU. Additionally, FEFCO welcomes the packaging minimisation measures and proposed empty space ratio as they will help to reduce packaging waste. The industry prides itself on offering fit for purpose packaging and has worked with manufacturers to ensure that corrugated cardboard packaging is optimised to its fullest extent while still protecting products.

…to ensure that corrugated cardboard packaging is optimised to its fullest extent while still protecting products. However, FEFCO also has concerns regarding several of the proposal’s key measures, including the reuse targets (Article 26) and the market restrictions on certain packaging types (Article 22, Annex V). Please see FEFCO’s position paper further elaborating on our main concerns. The Regulation should aim to make packaging more circular in a holistic way without giving certain materials a disproportionate market advantage. Material neutrality would be better maintained if the legislation were to consider recycling and reuse as equally viable options for packaging circularity.

…maintained if the legislation were to consider recycling and reuse as equally viable options for packaging circularity. Based on our reading of the Impact Assessment (IA) for the PPWR, FEFCO does not feel that sufficient evidence or transparency has been provided to justify some of the proposed targets; for example, there is a concerning lack of consideration for certain elements in the assessment of reuse targets, including food safety, hygiene and the substitution effect between materials. We therefore would like to provide specific feedback on elements of the IA that are misleading and inconsistent.

We therefore would like to provide specific feedback on elements of the IA that are misleading and inconsistent. Feedback on the Impact Assessment of the PPWR • IA Part 1, Page 3: Misleading wording regarding use of virgin material “…there are environmental concerns: packaging is a key user of virgin materials (40% of plastics and 50% of paper use in the EU is for packaging) and packaging represents 36% of municipal solid waste.” FEFCO comment: The wording of the statement above implies that paper packaging is made from 50% virgin material. This is incorrect as paper packaging currently has an average recycled content of 75%, meaning the average virgin input is only 25%. In the case of corrugated board, the average recycled content is 89% with a virgin input of about 11%. This should be clarified in the IA and the text of the Regulation.

…is 89% with a virgin input of about 11%. This should be clarified in the IA and the text of the Regulation. • IA Part 1, Page 9: Incorrect framing of paper/board “…In e-commerce, over-packaging is even more evident…Moreover, light-weighting of packaging has been accompanied by a shift to materials with a worse environmental footprint, particularly from metal and glass to plastic and paper/board.” FEFCO comment: The assumption that metal and glass have a better environmental footprint than paper and board is misleading, especially given the mention of e-commerce right before. Glass and metal cannot be used for many packaging applications, namely e-commerce packaging. Paper and board packaging is highly recyclable and has a high recycling rate and recycled content, the same of which cannot be said for plastic.

…is highly recyclable and has a high recycling rate and recycled content, the same of which cannot be said for plastic. Grouping paper and board in with plastic as a material with a ‘worse environmental footprint’ is therefore misleading. Ref. Ares(2023)2829414 - 21/04/2023 2 • IA Part 1, Page 12: Misleading assumption that economies of scale are not possible with current waste management systems “Moreover, due to the scattered sorting and recycling markets, there is limited potential for economies of scale. In the absence of a clear legal framework incentivising circularity of packaging, there is also an investment risk for the recycling industry.

…legal framework incentivising circularity of packaging, there is also an investment risk for the recycling industry. The industry is cautious to invest in new technologies and unable to achieve economies of scale for innovative activities.” FEFCO comment: Paper & board is already recycled at scale across the EU due to its efficient collection, sorting and existing recycling infrastructure. According to Eurostat, paper & board has the highest recycling rate among materials at 82% (2019). An efficient separate collection system is a prerequisite for recycling and will help boost investments in bettering recycling infrastructures.

…system is a prerequisite for recycling and will help boost investments in bettering recycling infrastructures. • IA Part 1, Page 12: Acknowledgement that waste management and reuse systems are not always cost effective “…closed pool systems, where the reusable packaging has to go back to the initial packer, might be less environmentally beneficial than single use packaging, if the transport distance is very big, or be a risk for food hygiene.” FEFCO comments: The IA clearly states that transport distances and hygiene issues can result in reuse systems not being environmentally sound compared to single-use options.

…and hygiene issues can result in reuse systems not being environmentally sound compared to single-use options. These concerns are not adequately addressed when the reuse targets are later assessed, therefore the benefits of the final targets (for example, the targets for reusable transport packaging in Article 26.12 and 26.13 which could apply to food contact products) were not sufficiently proven by the IA. • IA Part 1, Page 24: Incomplete justification for targets for household appliances “The set of mandatory and strict targets, e.g.

Page 24: Incomplete justification for targets for household appliances “The set of mandatory and strict targets, e.g. 100%, would have as a consequence that businesses which only produce single-use packaging for the market in question… would be thus at risk of closure…high level targets (90%) have been introduced, these do not refer to the producers that they can sell their products only in single use packaging… this selection was discussed with the concerned stakeholders and the specific targets were chosen in cooperation.” FEFCO comment: Based on the justification provided, it is clear that the impact on single-use packaging was not evaluated for this measure, as a 90% target is enough for closure of business which provides packaging for this market. The existing production lines will not continue to operate if they are only able to serve 10% of the market, resulting in closure.

…production lines will not continue to operate if they are only able to serve 10% of the market, resulting in closure. This makes the IA’s reasoning incomplete. Despite what the IA claims, FEFCO was not consulted on this measure although corrugated cardboard provides a significant amount of packaging from this market segment. • IA Part 1, Page 25: Justification of proposed reuse targets lacking evidence “The whole set of the reuse measures is designed to set feasible targets and to avoid that the transport of the emptied reusable packaging does not devour the environmental benefits, neither undermine the safety of the packaged products.” FEFCO comment: This section acknowledges that reuse systems risk having a negative environmental effect and claims the measures have taken this into consideration. However, no evidence is provided for most of the measures.

…and claims the measures have taken this into consideration. However, no evidence is provided for most of the measures. In the case of the transport packaging targets, there is no indication that the return of empty reusable packaging would not increase transport emissions or that reusable options would protect products better than recyclable single-use options. 3 • IA Part 2, Page 58: Reuse leads to more GHG emissions “…The reduction in recycling has the opposite impact – resulting in a net gain in GHG emissions, as reduced recycling leads to a decrease in avoided GHG emissions (i.e., recycling activities would have led to negative emissions had they taken place, via the reduced use of raw materials in subsequent manufacturing). Increased deployment of reuse programmes also leads to increased GHG emissions, mainly due to the transportation of reusable packaging.

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European Federation of Corrugated Board Manufacturers 250 Avenue Louise, 1050 Brussels, Belgium  Tel: +32 2 646 40 70 www.fefco.org  VAT BE 0477 487 844 7 January 2026 Statement and proposed amendment on the draft delegated act to establish exemptions from the PPWR’s reuse obligations for wrappings and straps. FEFCO supports the 100% exemption from the PPWR’s reuse obligations for wrappings and straps for all materials, and proposes the following amendment: Commission proposal FEFCO amendement Article 1 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.

…the 100% reuse requirements of these packaging formats established in 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(1), (2) and (3) of Regulation (EU) 2025/40”. Justification : Reuse targets on wrappings and straps are economically and technically unfeasible. No adequate reusable systems currently exist, as confirmed by the Deloitte study and return logistics and infrastructure for reusable packaging are absent. In addition, automated solutions for reusable packaging are not sufficiently developed yet.

…packaging are absent. In addition, automated solutions for reusable packaging are not sufficiently developed yet. Granting a full exemption for pallet wrappings and straps is the most sensible and practical solution. This measure ensures the protection of products, upholds hygiene standards, and supports worker safety, all while preserving the cost efficiency of supply chains throughout Europe. Such an exemption is consistent with the main objectives of the PPWR and avoids placing unnecessary burdens on economic operators. FEFCO members, use wrapping and straps to ship their products and the reuse targets on those would create unnecessary costs and ergonomic risks.

…and straps to ship their products and the reuse targets on those would create unnecessary costs and ergonomic risks. Within the food supply chain, maintaining hygiene standards makes the reuse of wrappings and straps even more challenging considering that the process of cleaning demands significant resources and expense, and the materials often degrade quickly, leading to disposal and increased waste generation. Ref. Ares(2026)166128 - 08/01/2026 European Federation of Corrugated Board Manufacturers 250 Avenue Louise, 1050 Brussels, Belgium  Tel: +32 2 646 40 70 www.fefco.org  VAT BE 0477 487 844 Furthermore, limiting exemptions to intra-Member State transport disadvantage export- driven industries in countries that are export intensive. For many EU countries, export is essential to their commercial activities.

…in countries that are export intensive. For many EU countries, export is essential to their commercial activities. By limiting the exemptions for transport only within the same Member State penalises those countries, in a disproportionate way. They will face inability to comply with the provisions thus undermining competitiveness and proportionality. ----- About FEFCO: FEFCO members produce corrugated cardboard packaging which is used to pack and protect over 75% of European goods as sales, grouped and transport packaging. For all those shipments wrappings and straps are used to secure the loads. Corrugated cardboard packaging is a unique example of circularity; it is collected and recycled all over Europe. Indeed, the recycling rate of corrugated cardboard in Europe is at least 87% (Eurostat 2023) and it has an average recycled content of 88% (FEFCO LCA 2021).

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…1 Feedback to the European Commission public consultation “Review of the requirements for packaging and other measures to prevent packaging waste” The undersigned associations support the Commission’s ambition to contribute to the circular economy through the review of the requirements for packaging and packaging waste. A future-proof Packaging and Packaging Waste Directive (PPWD) should take an outcome-based approach to enable that all packaging is recyclable or reusable and low-carbon. This should be done by setting ambitious and clear goals, while safeguarding the well-functioning of the Internal Market and enabling industry to innovate.

…and clear goals, while safeguarding the well-functioning of the Internal Market and enabling industry to innovate. The revised PPWD should be based on a set of principles and objectives which achieve the following: • Set goals to support separate collection, sorting and recycling and waste reduction with a focus on reducing residual waste that is not recycled or reused. • Provide clear definitions for the concepts and terms referred to (e.g. recyclable packaging, reusable packaging); • Support the EU’s transition towards a strategic resource autonomy, which reduces our dependency on imported materials; • Ensure a level-playing field for the packaging sector through a technology/material neutral approach and non-discrimination. Life Cycle Assessment (LCA) studies can be useful in this respect to measure environmental performance while taking into account the end of life of packaging.

…be useful in this respect to measure environmental performance while taking into account the end of life of packaging. For accurate results, LCAs should look at packaging formats in the same packaging category. • Ensure a level playing field for European producers with respect to imported packaging materials. • Ensure a stable regulatory framework for industry to invest in sustainable innovations of packaging solutions, which otherwise would not be achieved through restrictions on materials or packaging options; • Ensure the integrity and well-functioning of the EU Internal Market through clear and realistic EU requirements and legislation that foster competition. Paper and paperboard packaging is designed with a plurality of purposes, benefits and functions.

…foster competition. Paper and paperboard packaging is designed with a plurality of purposes, benefits and functions. To this extent, the revised Essential Requirements for packaging in the upcoming PPWD legislation must strike the right balance between the functionality of packaging and the objectives of packaging circularity and waste reduction, and therefore, achieve the following: Ensure a level-playing field for all materials and packaging. The revised PPWD should provide objectives and targets which improve the circularity and climate impact of packaging lagging in performance in its product category, while supporting innovation in sustainable and already circular materials, such as paper packaging, and enabling the well-functioning of the EU’s Internal Market.

…and already circular materials, such as paper packaging, and enabling the well-functioning of the EU’s Internal Market. Ensure a clear, practical and enforceable definition of “recyclable” packaging, which focuses on design for high-quality recycling. High quality recycling is understood as using paper for recycling for the production of new paper-based products. The paper and board sector already incorporates eco-design to ensure that packaging is recyclable and recycled at scale. Measures to promote recycled content should be applied for target sectors where the markets for secondary raw materials are not developed yet, and be underpinned by existing market and product realities.

…markets for secondary raw materials are not developed yet, and be underpinned by existing market and product realities. Measures on recycled content should not disturb well-functioning recycling loops, such as paper and board recycling, and should be assessed based on a robust impact assessment that accounts for market conditions and existing authorisations, particularly with regard to food contact applications as food safety and hygiene should not be compromised. The market for paper for recycling is already well-developed, as shown by the high recycling rate of 84.6%1. There is a ‘real’ economic demand for recycled paper as a secondary raw material allowing the fibres to remain in the economy as a valuable resource and be used for new paper – based packaging. 1 According to Eurostat figures, https://ec.europa.eu/eurostat/databrowser/view/ten00063/default/table?lang=en Ref.

…1 According to Eurostat figures, https://ec.europa.eu/eurostat/databrowser/view/ten00063/default/table?lang=en Ref. Ares(2021)120077 - 07/01/2021 2 Furthermore, a future-proof PPWD should strike the right balance between waste prevention, reusability or recyclability of packaging, and thus: Ensure that waste prevention targets for packaging focus on the stream of residual packaging waste, i.e. waste that cannot be reused or recycled. An “overall packaging waste reduction target or waste generation limit” with the aim of reducing the volume or weight of packaging waste is counterproductive to the economy as a whole and has higher impact on the environment. A qualitative approach targeted on packaging efficiency should prevail on a purely quantitative one.

…the environment. A qualitative approach targeted on packaging efficiency should prevail on a purely quantitative one. Well designed, responsibly sourced, efficiently produced, low-carbon packaging that is appropriately used and effectively recycled provides multiple benefits – it minimises damage to products and food waste, extends their useful life, facilitates efficient distribution, gives safe and convenient access to goods and communicates vital information to the consumer. Ensure that future measures on packaging reuse take into account all environmental, health and economic impact of reuse systems throughout the life cycle of the product and packaging, assessing the different options through LCA and compared performances. End of life should be taken into account in both cases.

…the different options through LCA and compared performances. End of life should be taken into account in both cases. EU regulators should avoid setting reuse targets for “transport packaging”, as this approach would jeopardise already well-functioning recycling and circular systems by including packaging already recycled at very high rate. Address packaging waste prevention through measures underpinned by their impact on climate change, biodiversity and in light of the essential function of packaging to ensure and support resilient and sustainable supply chains. Reduce “overpackaging” by enabling packaging which is “fit for purpose”: circular packaging designed according to its functionality, which prevents product and food losses as well as packaging waste.

…packaging designed according to its functionality, which prevents product and food losses as well as packaging waste. Equally, restricting the use of specific packaging formats, like single use packaging items is an approach which does not deliver long-term benefits, nor a forward-looking solution to sustainability. Single use packaging as a format includes packaging made from different materials, with different threats to the environment and the oceans and should not be regulated as one single category. Recyclable, low-carbon single use packaging made from sustainably sourced renewable materials should be incentivised, not restricted. Single use packaging including for food contact materials has clear hygienic advantages when it comes to food and consumer safety and is essential for the overall resilience and sustainability of the food system. Brussels, 17 December 2020

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…1 Feedback to the EU Inception Impact Assessment on the initiative “Review of the requirements for packaging and other measures to prevent packaging waste” The undersigned associations support the Commission’s ambition to contribute to the circular economy through the review of the requirements for packaging and packaging waste. The review should also ensure that the proposed preventive measures will support the functioning of the internal market and free movement of packaging and packaged goods while preventing the possible negative impact on the environment.  Measures on packaging prevention should be meaningful, achievable, and supporting the overall objective of the EU Green Deal and Circular Economy. All new measures need to be exhaustively assessed on their impact on climate change, biodiversity and the functioning of resilient and sustainable food supply chains.

…on their impact on climate change, biodiversity and the functioning of resilient and sustainable food supply chains.  A level-playing field for all materials and packaging should be maintained as a pre-requisite for the functioning of the internal market. The EU legislation should provide objectives and targets to improve the circularity and climate impact of packaging lagging in performance and at the same time support further innovation in sustainable materials which are already circular – like paper packaging.  Paper & board packaging is the most recycled packaging in Europe with 85% of recycling rate in 2018, according to Eurostat. There is a ‘real’ economic demand for recycled paper as a secondary raw material allowing the fibres to remain in the economy as a valuable resource and be used for new packaging.

…raw material allowing the fibres to remain in the economy as a valuable resource and be used for new packaging.  We support setting a practical and enforceable definition of “recyclable” packaging. Such a definition should focus on Design for high quality recycling. In the paper sector, high quality recycling is understood as using paper for recycling for the production of new paper-based products. The paper & board sector already incorporates eco-design to ensure that packaging is recyclable and recycled in practice and at scale. In addition, we support the net-cost principle and general requirements on harmonized EPR systems, including eco-modulation to incentivize more easily recycled packaging.  We support the reduction of “overpackaging”. Packaging “fit for purpose” prevents waste and should be introduced as a new measure for all packaging.

Packaging “fit for purpose” prevents waste and should be introduced as a new measure for all packaging. This will ensure that every packaging is designed to fit the product exactly with minimum void space, thus preventing overpackaging and underpackaging and the related unnecessary waste and losses. Packaging need to meet functionalities and avoid product or food losses which in some cases require an adapted composition.  Setting an “overall packaging waste reduction target or waste generation limit” with the aim of reducing the volume or weight of packaging waste is counterproductive to the economy as a whole and has higher impact on the environment. o The targets to reduce packaging should focus on the stream of residual packaging waste, i.e. waste that cannot be reused or recycled and is therefore landfilled or incinerated.

…of residual packaging waste, i.e. waste that cannot be reused or recycled and is therefore landfilled or incinerated. o Well designed, responsibly sourced, efficiently produced, low-carbon packaging that is appropriately used and effectively recycled provides multiple benefits – it minimises damage to products, extends their useful life, Ref. Ares(2020)3790509 - 17/07/2020 2 facilitates efficient distribution, gives safe and convenient access to goods and communicates vital information to the consumer.  Restricting the use of specific packaging formats, like single use packaging items is a short-sighted approach which do not offer a sustainable solution and should be avoided. o Single use packaging as a format includes packaging made from different materials, which do not pose the same threat to the environment and the oceans and should not be regulated as one single category.

…which do not pose the same threat to the environment and the oceans and should not be regulated as one single category. Recyclable, low-carbon single use packaging made from renewable materials should be excluded from such restrictions. o Single use packaging including for food contact materials has clear hygienic advantages when it comes to food and consumer safety and is essential for the overall resilience and sustainability of the food system, as it was also recently proved by the COVID-19 crisis.  Future measures on reuse should consider all environmental, health and economic impact of reuse systems throughout the life cycle of the product and packaging. Setting reuse targets for “transport packaging” as a format risks to include packaging which is already being recycled at very high rate and thus jeopardizing a well- functioning and circular system.

…is already being recycled at very high rate and thus jeopardizing a well- functioning and circular system.  Measures to promote mandatory recycled content should target sectors where the markets for secondary raw materials are not developed yet. The market for paper for recycling already well-developed, as shown by the high recycling rate. Measures on mandatory recycled content are unnecessary and may have unintended impact disturbing the functioning recycling system. Moreover, as for all other materials, the recycling loop also needs to be reinforced by fresh fibre flows.  Green procurement criteria and targets could be introduced to support not only the public bodies but all businesses who would like to include sustainability in their packaging procurement strategies. Brussels, 15 July 2020.

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