Fédération belge des industries chimiques et des sciences de la vie

© 02 December 2020 1-2 PPWD PUBLIC CONSULTATION ON THE REVIEW OF THE REQUIREMENTS FOR PACKAGING This document provides additional comments from essenscia to the Public consultation on reducing packaging waste – review of rules. This document is prepared and meant to be read in conjunction with the replies provided by essenscia in the main questionnaire, in addition to the comments below specific questions. 1 About the questions Several questions, especially in the General Section, have been formulated in a way which may induce a bias and may be therefore considered as misleading. Our comments will attempt to clarify some of them. Level of effectiveness and efficiency contains contradictory terms for assessment.

…attempt to clarify some of them. Level of effectiveness and efficiency contains contradictory terms for assessment. 2 About the spirit of the law Although the revision of the PPWD is happening while the circular economy principles are deployed, PPWD has been drafted to fit the linear economy principles. There is, therefore, an additional challenge to the revision. The linear principle of this legislation requires, as much as possible, the recovery of recoverable materials from waste, i.e. products that have been used. The spirit of the law is to reduce the consumption of resources that end up as waste. The circular principle sets a new spirit to the law, suggesting optimising the use of resources and reducing the use of so- called virgin resources. The circular principle encompasses the linear principle.

…resources and reducing the use of so- called virgin resources. The circular principle encompasses the linear principle. 3 About hygiene, health safety and prevention of food waste Several general questions suggest that the reusable option is, per se, beneficiary to society. However, the questions fail to address the concern of • Hygiene: how the reusable container is washed and at what environmental cost • Health safety: open container should be used with all necessary safety procedure to avoid contamination, in a non-hygienic environment (bulk shops open to the public) • Food waste prevention: more and more scientific studies confirm that the ultimate goal of the packaging to preserve essential natural resources is to reduce as much as possible, on the long term, food waste.

…the packaging to preserve essential natural resources is to reduce as much as possible, on the long term, food waste. Moreover, when asking about alternative materials like metal or bamboo, the questions are not addressing actual concerns • Metal may alter the taste of the content, which is against any food regulations. • Bamboos or wood are considered as an issue in Belgian and European legislations as melamine or formaldehyde leach out of the material to the food/beverage, both substances considered as substances of concern. 4 About necessary packaging The questionnaire, in both Sections 2 and 3, refers to packaging and the concept of necessity to protect the product or ensure hygiene. This is an obvious reduction in scope compared to the stated provisions in the legislation itself.

…or ensure hygiene. This is an obvious reduction in scope compared to the stated provisions in the legislation itself. Packaging fulfils many other functions and provide certain guarantees to the packed good: from transport efficiency to safety, to extension of shelf life in case of food packaging, mandatory information (use, safety, composition, handling as waste, …). The concept of ‘necessity’ as referred to packaging is not defined in the relevant legislation and is therefore subjective. 5 About Green Public Procurement In reference to the requirement of public authority buyers to purchase products using reusable, recyclable and returnable packaging options or products with recycled content, essenscia would like to remind that this policy must be compliant with an effective environmental and social benefit, suggesting therefore the reasonability of its implementation.

…an effective environmental and social benefit, suggesting therefore the reasonability of its implementation. Returnable packaging may not be the most resources saving solution. Imposing recycled content quantity is, per definition, limited by the availability on the market of the right quantity and quality covering the observance of the applicable regulatory framework related to the intended application. Ref. Ares(2020)7507262 - 10/12/2020 © Dec 2020 The information hereby provided is assumed to be accurate to the best of our knowledge at the date of the last revision. essenscia cannot be held responsible for related changes, inaccuracy, or misuse of this information.

…the last revision. essenscia cannot be held responsible for related changes, inaccuracy, or misuse of this information. essenscia Bluepoint Boulevard Auguste Reyerslaan 80 B-1030 Brussel/Bruxelles T +32 2 238 97 11 F +32 2 231 13 01 www.essenscia.be [email protected] Belgische federatie van de chemische industrie en van life science VZW Fédération belge des industries chimiques et des sciences de la vie ASBL 6 About additional measures The effectiveness of recyclability (question 15, Section 3) depends on the recycling scheme, as several methods are leading to the disappearance of the tracer or even to the recovery of the genuine substances to produce monomers.

…are leading to the disappearance of the tracer or even to the recovery of the genuine substances to produce monomers. The circularity, recovery and recycling of plastic materials is achieved through the combination of different techniques of • Mechanical recycling, including sorting optimisation for which marking may be used • Cleaning, such as washing, deinking, etc.

…recycling, including sorting optimisation for which marking may be used • Cleaning, such as washing, deinking, etc. • Purification before recycling by selective dissolution or extraction of substances • Chemical recycling for partial or total depolymerisation down to the basic substances • Purification before use in products These developments are depending on • The observance of REACH • The availability of authorised processes for safe use of recyclate • The recycled content book-keeping • The certification of recycled content for any material It is important to make relevant decisions on recyclability and best environmental performance must be based on impact assessments (such as LCAs), covering every aspect of the environmental impacts, while prioritising CO2 emissions savings in the use of a type of packaging, Such assessments for well informed decisions also rely on harmonise…

…of EPR fees) and consider that the whole recyclability topic is only one facet of a sustainability of packaging. Each type of packaging, material or polymer has a legitimate reason to exist and provide different characteristics for the expected functionality. 7 About the COVID19 effects The Covid19 event less impacted the packaging plastic industry compared to the other plastic converters. However, data may suggest an increase of domestic uses for food and health. Companies that produce packaging for essential goods such as food and beverages have seen a temporary increase in demand during the stockpiling at the beginning of the pandemic. Following the run on supermarkets, consumers are well supplied and demand for plastic packaging is expected to have declined already in April 2020.

…consumers are well supplied and demand for plastic packaging is expected to have declined already in April 2020. The demand for packaging in the medical and hygiene sector has increased as well and is expected to stay on a high level more constantly. On the other hand, companies that produce packaging for industrial and professional applications have seen a sharp decline in demand due to the reduced activities of their customers. The changes in plastic converting overall productions lead to several disruptions on the market and on the prices of resources, including the economically uptake of recycled materials which are not necessarily used for packaging with respect to the properties of the recycled polymer or to the law.

…which are not necessarily used for packaging with respect to the properties of the recycled polymer or to the law. The current lack of demand is expected to last at least for the first half of 2021, related to the reduction of production in the industry or to the closure of retail shops while the care sector due to the restrictive measures adopted by the national governments. The disruption also affect worldwide exports and EU competitiveness as the Covid19 event is managed differently in the world. The lack of demand implies production disruptions, but most fixed costs remain. Furthermore, the companies have to bear added cost to operate given the additional actions to minimise the contamination potential. Now the situation remains difficult and there is uncertainty for the coming year.

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…essenscia Silver Building Boulevard Auguste Reyerslaan 70 B-1030 Brussel/Bruxelles T +32 (0)2 238 97 11 www.essenscia.be [email protected] Belgische federatie van de chemische industrie en van life sciences VZW Fédération belge des industries chimiques et des sciences de la vie ASBL Brussels, January 8th 2026. Feedback on the proposal for exemption of certain operators that use pallet wrappings and straps from the 100% reuse requirements of these packaging formats – (2025/40 – PPWR) essenscia welcomes the Commission’s draft Delegated Decision exempting economic operators using pallet wrappings and straps from the 100% reuse obligations under Article 29(2) and (3) of the PPWR. However, scientific, technical and economic evidence shows that pallet wrappings and straps should be excluded altogether from reuse targets under Article 29(1), (2) and (3).

…that pallet wrappings and straps should be excluded altogether from reuse targets under Article 29(1), (2) and (3). Limiting relief to specific operators does not resolve the fundamental flaws of applying reuse requirements to these packaging formats. The Delegated Decision relies solely on Article 29(18)(a) PPWR, which addresses economic difficulties but does not assess environmental performance. Yet Article 29(18)(c) expressly allows exemptions where environmental considerations justify them. In this regard, essenscia refers to the ISO-compliant life-cycle assessment by IFEU (April 2025), which concludes that optimised single-use plastic pallet-wrapping systems outperform reusable alternatives across key environmental indicators, including climate change. Reusable solutions require heavier and less flexible materials, leading to higher resource use and logistical inefficiencies.

…solutions require heavier and less flexible materials, leading to higher resource use and logistical inefficiencies. These findings are confirmed by the Deloitte feasibility study for the Commission, which also identifies higher greenhouse-gas emissions in reuse scenarios. Together, this evidence supports an exemption for pallet wrappings and straps under Article 29(18)(c). Significant technical and safety constraints further prevent reuse. Pallet wrapping is essential for load stability and transport safety. According to EUMOS, manually applied reusable sleeves fail to meet the EUMOS 40509 load-stability standard for heavy or irregular loads, while automated single-use systems обеспеч consistent and verifiable safety performance.

…for heavy or irregular loads, while automated single-use systems обеспеч consistent and verifiable safety performance. No standardised, high-speed, automated reusable pallet-wrapping solutions exist at industrial scale, and current reusable concepts are incompatible with modern, high-throughput production environments. For strapping, the Fraunhofer study (April 2025) shows a 47–60% loss of strength at the weld point after a single use, with damage not visually detectable. Reuse therefore creates incalculable safety risks and liability concerns. The study concludes that reuse of strapping is not technically recommended. Further studies by GVM and IFEU confirm that single-use pallet strapping—already lightweight, highly recyclable and containing high levels of PCR—provides a safer and more environmentally sound solution.

…highly recyclable and containing high levels of PCR—provides a safer and more environmentally sound solution. Reusable alternatives are also not recyclable under current conditions, contrary to the requirements in Article 6 of the PPWR. Despite the proposed Delegated Decision, significant economic burdens remain because pallet wrappings and straps would still fall under the 40% reuse quota of Article 29(1). Including these formats in the average reuse calculation would impose disproportionate costs, reduce competitiveness, and especially disadvantage EU operators vis-à-vis non-EU competitors. Companies using pallets, wrapping and straps Ref.

…especially disadvantage EU operators vis-à-vis non-EU competitors. Companies using pallets, wrapping and straps Ref. Ares(2026)179119 - 08/01/2026 essenscia Silver Building Boulevard Auguste Reyerslaan 70 B-1030 Brussel/Bruxelles T +32 (0)2 238 97 11 www.essenscia.be [email protected] Belgische federatie van de chemische industrie en van life sciences VZW Fédération belge des industries chimiques et des sciences de la vie ASBL would fail to meet the average reuse requirement even under optimal conditions. Many operators cannot compensate by increasing reuse of other packaging formats and would be forced to operate parallel packaging systems for EU and export markets, at substantial cost.

…formats and would be forced to operate parallel packaging systems for EU and export markets, at substantial cost. Additional administrative burdens arise from unclear reporting obligations, notably the calculation of “equivalent units” for pallet wrappings and straps, as well as unresolved questions regarding enforcement for imported goods. As long as Article 29(1) applies, companies will face ongoing investment, operational complexity and compliance costs that significantly undermine the effectiveness of the proposed exemption. Conclusion essenscia considers the draft Delegated Decision a necessary first step but urges the Commission to fully exclude pallet wrappings and straps as packaging formats from all reuse obligations under Article 29(1), (2) and (3), in line with environmental evidence, technical feasibility, load-safety requirements and competitiveness concerns.

(3), in line with environmental evidence, technical feasibility, load-safety requirements and competitiveness concerns. essenscia is the Belgian sector federation for the chemical industry and life sciences. The organisation represents the specific interests of companies active in chemicals, plastics, pharmaceuticals and biotechnology.

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