Stichting CEFLEX

…1 9 January 2026 Submission to public consultation on a draft Delegated Decision exempting pallet wrappings or straps from PPWR Article 29 paragraphs 2 & 3 • CEFLEX welcomes the proposed Delegated Decision exempting economic operators using pallet wrappings and straps from the 100% reuse requirement for these formats in PPWR Article 29 paragraphs 2 and 3. • In addition to the costs of adapting to reusable substitutes for pallet wrap, we consider that threats of disruption to food supply chains and damage to plastics recycling value constitute economic constraints justify the exemption. • Due to a lack of data and the current absence of a reuse calculation method, we are unable to assess the impact of the 40% target in PPWR Article 29 paragraph 1 on flexible packaging circularity.

…we are unable to assess the impact of the 40% target in PPWR Article 29 paragraph 1 on flexible packaging circularity. We therefore consider that it is not currently possible to say as a matter of fact that “operators can compensate a used format with a low re-use rate with one that has a high re-use rate”. However, we support the Commission’s intention and therefore recommend to amend this phrase in Recital 1 and insert a new Article to the draft Delegated Decision to ensure that the statement holds true in future. • Clarification and confirmation is sought that shrink and stretch hoods are classified as pallet wrapping. Context Starting in 2030, the Packaging and Packaging Waste Regulation (PPWR) requires that pallet wrappings and straps be reusable under certain conditions.

…and Packaging Waste Regulation (PPWR) requires that pallet wrappings and straps be reusable under certain conditions. Article 29.1 requires economic operators to ensure that 40% of specific transport packaging types—including pallet wrappings and straps—and sales packaging used to transport products in the EU is reusable. According to Article 29.2, 100% of such packaging used to transport products within a Member State must be reusable. Similarly, Article 29.3 extends this 100% requirement to packaging used for transportation between an operator’s own sites and those of a partner enterprise. Pallet wrap, due to its stretch and shrink properties, is inherently non-reusable. The requirement for all pallet wrappings and straps to be reusable thus necessitates a shift to alternative solutions. Ref.

…requirement for all pallet wrappings and straps to be reusable thus necessitates a shift to alternative solutions. Ref. Ares(2026)228822 - 09/01/2026 2 Reusable packaging operates within a distinct logistical system, requiring collection, cleaning, and redistribution. It is impractical for companies to maintain both single-use and reusable packaging systems simultaneously. Consequently, Article 29 paragraphs 2 and 3 of the PPWR effectively result in a de facto ban on pallet wrap and straps in the EU starting in 2030. Grounds for an Exemption from PPWR Article 29 Paragraphs 2 and 3 CEFLEX acknowledges the Commission’s assessment that transitioning to 100% reusable pallet wrappings and straps could lead to disproportionate adaptation costs for economic operators.

…to 100% reusable pallet wrappings and straps could lead to disproportionate adaptation costs for economic operators. Therefore, the exemption for economic operators is justified on grounds of particular economic constraints under Article 29 paragraph 18.a. In addition to the costs of adaptation mentioned in Recital 3 of the draft Delegated Act, we believe that the exemption will prove to be justified by economic constraints on the food value chain and the plastics recycling sector, which is already in crisis. Threat of Knock-on Effects on Food Supply Chains From a flexible packaging perspective, recent CEFLEX research indicates that plastic stretch and shrink films are projected to become the single largest secondary market for recycled polyolefin-based flexible packaging from 2030 onwards, representing around 30% of total PCR demand for flexible packaging-derived recyclate.

…packaging from 2030 onwards, representing around 30% of total PCR demand for flexible packaging-derived recyclate. While not all stretch and shrink films are used in logistics, experts estimate that roughly 40% could be pallet wrapping. See graphics on the following pages for further details. If these estimates are broadly correct, losing pallet wrapping as an outlet for PCR would undermine flexible packaging’s transition to circularity. Pallet wrap is a high-volume, technically suitable application for recycled flexible plastic packaging, and therefore central to sustaining the business case for recycling. This type of secondary application cannot be replaced easily or quickly. Smaller outlets, even when innovative, cannot replicate the tonnage absorbed by the main film categories.

…or quickly. Smaller outlets, even when innovative, cannot replicate the tonnage absorbed by the main film categories. As flexible packaging recycling rates rise and recycled volumes increase, PCR quality becomes the key system variable: it determines which applications can use the secondary materials, in what volumes, and at what value. When PCR quality and secondary market requirements are misaligned, the whole system tightens: large outlets for standard PCR can saturate, while suitable new outlets may not exist at sufficient scale. By contrast, higher-quality PCR can meet more demanding performance requirements and will be used in non-contact-sensitive PE films, including stretch, shrink and collation films used in logistics and consumer packaging. This has implications for implementation of the PPWR.

…and collation films used in logistics and consumer packaging. This has implications for implementation of the PPWR. Now that the PPWR has established recycled content and recycled-at-scale requirements as a condition of market access, achieving them must be approached from a systems perspective—not as recycling “for its own sake”, but as a circular model that depends on robust secondary markets. For flexible packaging, that means the EU must maintain acceptance of secondary applications capable of absorbing large volumes, notably pallet wrap, shrink and collation films. If pallet wrapping were removed as an outlet for recycled content, flexible packaging users’ ability to comply with PPWR requirements would be significantly reduced.

…recycled content, flexible packaging users’ ability to comply with PPWR requirements would be significantly reduced. Given that flexible packaging represents around half of primary food packaging placed on the EU27+3 market, systemic non- compliance could also have unintended knock-on effects for food supply chains.

…on the EU27+3 market, systemic non- compliance could also have unintended knock-on effects for food supply chains. 3 3 % 1,420Kt Stretch and Shrink Film PE Refuse sacks PE ther bags and sacks PE op five PP applications Compression oulding P 43% 2,100Kt 2030 2030 203 203 203 2030 2030 2030 203 203 Estimated 2030 PCR demand and absorption op PE PP and P applications 9 % 0Kt 9 % 8 Kt 4 % 330Kt 7% 30Kt 3 % 320Kt 43% 470Kt (average) 31% 290Kt (average) 43% 420Kt 8% average increase in PCR content in this material stream from 2030 PCR Demand Estimated Recycled Content use 80Kt additional demand for stretch and shrink film from 2030 to 203 4 Previous page: PCR demand using flexible packaging-derived recyclate increases across the main applications. Each circle represents the size of demand in 2030 and 2035, and the proportion of recycled content expected in each material stream.

…the size of demand in 2030 and 2035, and the proportion of recycled content expected in each material stream. Stretch and shrink films remain the largest opportunity. Their combined PCR demand increases from about 1.42 million tonnes in 2030 to more than 2.1 million tonnes in 2035. And, as more recycled material has to be absorbed by the market – in large part due to PPWR recycling and recycled-at-scale targets – recycled content use increases from roughly thirty-five percent to more than forty percent.

…recycled-at-scale targets – recycled content use increases from roughly thirty-five percent to more than forty percent. Stretch film Shrink film Refuse sacks ther bags and sacks riented PP films eavy duty sacks Cast PP films Automotiv e 00 t 20% 2 0 t 10% 200 t 11% 1 0 t 19% t 2 % Demand growth to 203 10 t 2 t 2 % 2 t 2 % 100 t % Reduced Value of Plastics Recyclates As recycling commercial and industrial pallet wrappings produces more recycled output per tonne of input and generates less residual waste than recycling household flexible packaging, we estimate that the loss of pallet wrappings from the market would result in a 24% decline in mechanically recycled pellet from recycled flexible packaging.

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