Confederation of European Paper Industries

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)109998 - 07/01/2026 • 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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____________________________ About Fibre Packaging Europe Fibre Packaging Europe is an informal coalition of seven trade associations representing industries involved in forestry, pulp, paper, board and carton production and recycling from across Europe. Our joint mission is to provide renewable, circular and sustainable fibre-based packaging solutions to European citizens to achieve the European Green Deal objectives.

…sustainable fibre-based packaging solutions to European citizens to achieve the European Green Deal objectives. For more information, please contact [email protected] CEPI ECMA EPPA FEFCO PRO CARTON CEPI EUROKRAFT Alliance for Beverage Cartons and the Environment Position of Fibre Packaging Europe on the proposal for a Packaging and Packaging Waste Regulation (PPWR) Fibre Packaging Europe (FPE) is an informal coalition of seven trade associations representing industries involved in forestry, pulp, cardboard (paper, board and carton packaging) production and recycling in Europe, coming together to speak with one voice on the policy issues central to the fibre-packaging value chain in the EU.

…coming together to speak with one voice on the policy issues central to the fibre-packaging value chain in the EU. The fibre-based packaging sector acknowledges the European Commission’s proposal for a Packaging and Packaging Waste Regulation, and looks forward to supporting an evidence-based regulatory approach during the next stages of the legislative process. Both recyclable and reusable items have a role in the transition to a circular economy. Fibre-based recyclable packaging is produced from low-carbon renewable materials sourced from sustainably managed European forests and recycled at end-of-life.

…from low-carbon renewable materials sourced from sustainably managed European forests and recycled at end-of-life. Thanks to sustainable forest management, Europe can proudly claim that it currently has more forest resources than it did a century ago, with the forest area in Europe growing by 19.3 million hectares over the last 30 years.1 In fact, it is estimated that forests and the forest-based sector absorb around 20% of the EU’s total greenhouse gas emissions per year, contributing to the EU’s climate goals.2 Moreover, fibre-based packaging has a high recycling rate (81.6%)3 and is consequently already a key contributor to the circular economy.

…packaging has a high recycling rate (81.6%)3 and is consequently already a key contributor to the circular economy. 1) The industry should be involved in the drafting of the Design for Recycling Guidelines (DfR) in a systematic and transparent way through CEN FPE welcomes the proposed, actionable and forward-looking, definition of recyclability applicable to all packaging. However, the recyclability of the packaging must be assessed while taking into account material specificities via Design for Recycling (DfR) guidelines which provide technically sound guidance for recycling. The DfR should be based on expert judgment and consultation with targeted stakeholders, including recyclers, waste management operators, and technology providers.

…and consultation with targeted stakeholders, including recyclers, waste management operators, and technology providers. Thus, policymakers should ensure that stakeholders from the industry are consulted in a transparent and systemic manner in the drafting process of DfR guidelines. The paper and board recycling, manufacturing and converting industry, which has already invested into and developed recyclability guidelines4, has the knowledge and the expertise to support the development of DfR guidelines which will ensure recyclability by considering the packaging composition, functionality and suitability for recycling in existing streams and with existing technologies.

…packaging composition, functionality and suitability for recycling in existing streams and with existing technologies. A process within the independent standardisation body, European Committee for Standardisation (CEN), would allow for open cooperation and exchange of expertise to set ambitious and realistic requirements on packaging recyclability. 2) A mandatory 90% collection target for all packaging formats by 2030 is necessary to reach the recycled at scale obligation in 2035, further increase recycling rates and enhance the quality of the secondary raw materials The industry needs enabling conditions to ensure that packaging is recycled at scale by 2035. The first step to recycling is collection. It would be unjustified to ban packaging, as provided for in Art.

…by 2035. The first step to recycling is collection. It would be unjustified to ban packaging, as provided for in Art. 6 (2) (e) of the PPWR, if not recycled at scale in 2035 while the responsibility for collection does not rest with the industry. Such an obligation will penalise the industry, 1 The State of Europe's Forests, Forest Europe (2020) 2 Climate effects of the forest-based sector in the European Union, Peter Holmgren, FutureVistas AB (2020) 3 Recycling rate of packaging waste by type of packaging, EU27, 4 Paper-Based Packaging Recyclability Guidelines (Cepi, CITPA, ACE, FEFCO, 2019); Circularity by Design Guideline for Fibre-Based Packaging (4evergreen.eu, 2022) , FEFCO-Recyclability-Guidelines Final.pdf Ref. Ares(2023)2838282 - 21/04/2023 which has no control over the waste collection schemes available in each Member State.

Ares(2023)2838282 - 21/04/2023 which has no control over the waste collection schemes available in each Member State. Therefore, FPE calls for setting a mandatory 90% collection target for all packaging formats by 2030. EU-wide minimum requirements and a target for separate waste collection at 90% are necessary to further increase recycling and enhance the quality of the secondary raw materials. To achieve this, separate collection must be easy for consumers. From an operational point of view, FPE supports the principle that waste collection should rely on locally fit and efficient methodologies (e.g., kerbside collection rounds from households and businesses, acceptance in waste centres, etc.). In light of the above, used fibre-based packaging could be collected either in a single paper and board packaging stream or in a paper stream including graphic paper.

…could be collected either in a single paper and board packaging stream or in a paper stream including graphic paper. Beverage cartons could be collected in a separate lightweight stream or as part of a deposit refund system (where this would help reach high collection targets). human health and liability possible implications. 3) Recycling and reuse are complementary to create a circular economy. Policy decisions (including reuse targets) should be evidence-based. 4) FPE recognises that recyclable and reusable options are complementary towards a common goal of achieving a circular economy in the EU. Policy decisions (including reuse targets) should be founded on an evidence-based evaluation of the life- cycle impact of packaging, and its system, accompanied by the evaluation of the economic and technological implications, and consequences for human health and food security.

…by the evaluation of the economic and technological implications, and consequences for human health and food security. Importantly, fibre-based packaging has a critical function in protecting and preserving goods throughout the value chain, extending food lifespan5, and preventing product and food waste6 which contributes to resource efficiency7. Crucially, it safeguards consumer safety in logistics and on the shelf. In addition, it provides nutritional information and tells consumers how to store and prepare food safely. Paper-based products, particularly, contribute to expanding the shelf-life period of products often from hours to many days. 8Furthermore, packaging maintains the quality of sensitive products, such as milk and juices, which provide consumers with essential vitamins and nutrients.

…quality of sensitive products, such as milk and juices, which provide consumers with essential vitamins and nutrients. In some sectors (e.g., in food service systems or logistic systems) recyclable fibre packaging has a better environmental performance than reusable options9. As an example, according to the results of an in-depth and certified LCA study10 conducted by Ramboll, the reusable system in quick service restaurants generates 2.8 times more CO2-equivalent emissions, leads to 3.4 times more fossil resource depletion, consumes 3.4 times more freshwater and generates 2.2 times more fine particles compared to the fibre-based single-use system, thus, further accelerates climate change.

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