Stichting Golfkarton · Trade and business associations · NL
January 5th 2026. Support of the Netherlands and Belgium corrugated industry (branche Golfkarton verpakkingen) for the EU Commission’s proposed amendment on the draft delegated act to establish exemptions from the PPWR’s re-use obligations for pallet wrappings and straps ( in PPWR Art. 29 1, 29.2 and 29.3 ). The Netherlands and Belgium corrugated industry ( golfkarton verpakkingen) supports the 100% exemption from the PPWR’s re-use obligations for wrappings and straps for all materials, as no adequate re-usable systems currently exist, as confirmed by the Deloitte study. In addition, return logistics for these re-usable packaging are absent. Our company members of Stichting Golfkarton Industrie and also Corrugated Benelux Association (CBA), use wrapping and straps to ship their products.
Golfkarton Industrie and also Corrugated Benelux Association (CBA), use wrapping and straps to ship their products. The re-use targets on those wrappings and straps would create unnecessary costs and ergonomic (health) risks for the workers. Furthermore, limiting exemptions to only intra-Member State transport will disadvantage export-driven industries in countries that are export intensive. Netherlands and Belgium are export intensive countries. We therefore propose to add Art. 29.1 to the draft amendment. Stichting Golfkarton Industrie and Corrugated Benelux Association (CBA) support the draft amendment proposed by the EU Commission to Art. 1 of the Delegated Act. “Article 1 “Exemption concerning pallet wrappings and straps: .
…by the EU Commission to Art. 1 of the Delegated Act. “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% re-use requirements of these packaging formats established in Article 29(1), (2) and (3) of Regulation (EU) 2025/40”. Further substantiation / justification of our support and request: For many EU countries, export is essential to their commercial activities. By limiting the exemptions for transport of wrappings and straps to only within the same Member State penalises those countries, in a disproportionate way. They will face inability to comply with these provisions thus undermining competitiveness and proportionality and it will cause enormous logistical problems and extra costs for these companies. Ref.
…and proportionality and it will cause enormous logistical problems and extra costs for these companies. Ref. Ares(2026)39577 - 05/01/2026 Corrugated packaging companies in Europe produce corrugated cardboard packaging (golfkarton) which is used to pack and protect over 75% of European goods (sales, grouped and transport packaging). For all those shipments wrappings and straps are used to secure the load and so the workers’ health (prevent shifting of goods and therefore accidents). 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). In view of the above arguments we support the draft amendment of the EU Commission for the exemption of all wrappings and straps for re-use.
…we support the draft amendment of the EU Commission for the exemption of all wrappings and straps for re-use. Met vriendelijke groet, Peter M.M. van Ostaijen Directeur Stichting Golfkarton Stichting Belangenbehartiging Nederlandse Golfkartonindustrie Houtduiflaan 8 2261 CC Leidschendam-Voorburg [email protected] NL+31 (0)6 51 53 30 53 [email protected] www.golfkarton.org EU Transparency Register : REG 815099948248-86