European Plastics Converters Association

Avenue de Cortenbergh 71 - B-1000 Brussels • Phone: +32 (0)2 732 41 24 • Fax: +32 (0)2 732 42 18 [email protected] • www.plasticsconverters.eu Brussels, 21 April 2023 EuPC Position paper on the proposal for a new Packaging and Packaging Waste Regulation European Plastics Converters welcome the proposal of the European Commission for a new Packaging and Packaging Waste Regulation and are thankful for this opportunity to share some detailed comments.  Being a long legislative proposal with new and varied measures, we support the legal basis and legal instrument so to ensure the maximum harmonization among Member States. We stress that the possibility for Member States to adopt unilateral measures could heavily damage the free circulation of goods in the Single Market and be counterproductive for the implementation of this Regulation.

…the free circulation of goods in the Single Market and be counterproductive for the implementation of this Regulation.  We appreciate the need to have truly recyclable packaging placed on the market in line with existing and new recycling infrastructures with the double-step test (recyclability by design for recycling criteria and at scale requirement). Design for recycling criteria must ensure the participation of the industry (via standardization), while recycled at scale should be rather based on industrial capabilities. Since the test will eventually lead to some packaging out of the market, we suggest the deletion of Annex V as Article 6, with its evidence-based recyclability assessment, will clarify which packaging formats are effectively unrecyclable and hence are not allowed in the market.

…assessment, will clarify which packaging formats are effectively unrecyclable and hence are not allowed in the market.  The proposed recycled content targets appear very ambitious, nonetheless converters accept the challenge and aim at ensuring the safest and best uptake of recyclates per average per type of packaging format, by manufacturers1 , to allow for synchronization with real market conditions. The SUP Directive targets proved that the market does not provide for the quantity that are necessary to reach them thus resulting in a lack of availability of high-quality recyclates. For this reason, clarity on the safety nets provided by Article 7 par. 9 and 10 is fundamental to allow SMEs to be swiftly compliant with legislation.

…safety nets provided by Article 7 par. 9 and 10 is fundamental to allow SMEs to be swiftly compliant with legislation.  Some open questions still arise in relation to the accompanying Impact Assessment and the multiple measures dedicated to plastics only, where many data and causation links are not well 1 Manufacturer: the proposed definition of the PPWR includes both converters and brand owners that place packaging under their own name. Ref. Ares(2023)2837078 - 21/04/2023 Avenue de Cortenbergh 71 - B-1000 Brussels • Phone: +32 (0)2 732 41 24 • Fax: +32 (0)2 732 42 18 [email protected] • www.plasticsconverters.eu provided. We insist in calling the co-Legislators in considering better assessing some of the measures proposed and take into consideration life cycle assessments as well as availability of alternative options to back-up many proposals.

…into consideration life cycle assessments as well as availability of alternative options to back-up many proposals. One-size-fits-all approach for all types of packaging (primary, secondary and tertiary; B2C or B2B; flexible, rigid or semiflexible; expected use and circumstances) is not ideal nor desirable to ensure the best management of packaging formats and waste. ---- Impact Assessment As indicated in the European Parliament Briefing Appraisal on the IA and by the Regulatory Scrutiny Board, point raised as well by the ITRE Committee Chair, the Impact Assessment that supports the legislative proposal seems to not be fully aligned with the specific articles nor it is clear how certain conclusions have been drawn.

…seems to not be fully aligned with the specific articles nor it is clear how certain conclusions have been drawn. We think that a thorough and improved Impact Assessment should be conducted by the European Commission, taking into consideration intended consequences for the environment and switch effects to alternative materials, while better performance for certain packaging formats is not proved. Many proposed articles have not taken into consideration existing regulatory obligations (for example food contact legislation) nor packaging characteristics (product safety, hygiene, delivery type, waste prevention…). Legal basis and legal form As one type of economic operators placing packaging throughout Europe, we appreciate the possibility to have this Regulation (like the Packaging and Packaging Waste Directive in force) based on the free movement.

…have this Regulation (like the Packaging and Packaging Waste Directive in force) based on the free movement. This is pivotal to ensure there are no discrepancies among Member States and to finally stop the unilateral, overimplementing measures applied by single country that negatively affect the free circulation of goods. For the same reason, we support the choice of a regulation over a directive, as this will ensure that same rules apply to economic operators, public authorities and users/consumers in all Member States at the same time. The Single Use Plastics Directive and the divergent national implementation proved unfortunately that national preferences disrupt the European Single market and undermine the Green Deal objectives. Recyclability We appreciate Article 6 and the need to have packaging not only recyclable in theory, but also recycled in practice in Europe.

Article 6 and the need to have packaging not only recyclable in theory, but also recycled in practice in Europe. We look forward in being actively involved in the development of the Design for Recycling criteria, with the help of standardisation bodies and Circular Plastics Alliance’s working groups. Avenue de Cortenbergh 71 - B-1000 Brussels • Phone: +32 (0)2 732 41 24 • Fax: +32 (0)2 732 42 18 [email protected] • www.plasticsconverters.eu Plastics converters are already active in the ongoing activities at CEN on the recyclability standards for packaging and in the Dedicated Product Teams created by the Circular Plastics Alliance to work on design for recycling of various packaging types.

Product Teams created by the Circular Plastics Alliance to work on design for recycling of various packaging types. Clarification is though necessary to understand that the two-step approach proposed by the European Commission comes with a first deadline of 2035, by which D4R criteria and recyclability at scale will have to be demonstrated. We also understand that the recyclability text will lead to packaging formats that will not be considered as recyclable and hence not be allowed in the market. Therefore, some formats will be eventually prohibited as from 2035. Having this in mind, we believe that Article 22 should only cover those packaging formats for which their recyclability has not been proved, while not include those foreseen in Annex V.

…those packaging formats for which their recyclability has not been proved, while not include those foreseen in Annex V. The so-called negative list lacks coherence with the overall objective of the Regulation, nor it is clear on what grounds they should be restricted. Given the vast differences in consumption patterns among European nations and the fact that the type of packaging can vary greatly from one country to another, we believe that the proposed definition of “recyclable at scale”, more specifically the idea of "75% of the European population," is not up to the challenge of having all packaging recyclable at scale by 2035. For this reason, we suggest a more pragmatic definition based on industrial scale, provided separate collection is in place.

…reason, we suggest a more pragmatic definition based on industrial scale, provided separate collection is in place. Recycled content Plastics converters welcome and are ready to abide to the very ambitious recycled content targets, however there is a need to clarify how the targets will be implemented and by whom. The difficulty and administrative burden of calculating the percentages per unit of packaging, taking into account potential fluctuations in the supply of recycled material, was also noted by converters. We suggest that "unit of packaging" be replaced with a requirement for plastic waste per average, by packaging format (as defined in Annex II, Table 1) and by manufacturer, per year.

…for plastic waste per average, by packaging format (as defined in Annex II, Table 1) and by manufacturer, per year. Additionally, this will offer businesses the freedom to decide how much recycled material to use based on supply and technical viability, and it will be in line with the recycled content targets foreseen in the Single Use Plastics Directive. The proposal should also include the necessary framework conditions for the uptake of recycled content, such as standardized calculation methods and clear regulatory provisions to encourage investments in mechanical and chemical recycling, and increase the capacity of plastics for recycling. Many plastics converters have integrated plastic recycling facilities into their activities since many years with installed operational capacities of several millions of tonnes.

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Avenue de Cortenbergh 71 - B-1000 Brussels • Phone: +32 (0)2 732 41 24 • Fax: +32 (0)2 732 42 18 [email protected] • www.plasticsconverters.eu Page 1 of 4 9 January 2026 EuPC Feedback on the proposal for exemptions for pallet wrappings and straps from the 100% reuse requirements in the EU Regulation on packaging and packaging waste (2025/40 – PPWR) EuPC is the leading EU-level Trade Association, based in Brussels, representing European Plastics Converters. EuPC now totals about 51 national and European plastic converting associations, it represents close to 50,000 companies, producing over 50 million tons of plastic products every year. The European plastics industry makes a significant contribution to the welfare in Europe by enabling innovation, creating quality of life to citizens and facilitating resource efficiency and climate protection.

…enabling innovation, creating quality of life to citizens and facilitating resource efficiency and climate protection. More than 1.6 million people are working in about 50,000 companies (mainly small and medium sized companies in the converting sector) to create a turnover in excess of 280 billion € per year. EuPC supports the Commission’s draft Delegated Decision that relieves economic operators using pallet wrappings and straps from the obligation to meet the 100% reuse requirements set out in Article 29(2) and (3) of the Packaging and Packaging Waste Regulation (PPWR). This initiative corrects reuse requirements that were broadened late in the legislative process without being supported by a specific environmental or economic impact analysis for these applications.

…process without being supported by a specific environmental or economic impact analysis for these applications. Nevertheless, recent scientific research and economic assessments clearly demonstrate that pallet wrappings and straps should not fall within the scope of reuse targets under Article 29(1), (2) or (3). Limiting relief solely to certain economic operators (Article 29(2) and (3)) does not address the fundamental problems created by applying the reuse framework to these packaging formats in the reuse framework. Legal foundation and the need to consider environmental assessment The proposed Delegated Decision is based exclusively on Article 29(18)(a) of the PPWR, which allows exemptions where sectors face particular economic difficulties in achieving certain reuse targets.

PPWR, which allows exemptions where sectors face particular economic difficulties in achieving certain reuse targets. While this provision offers a lawful basis for the proposed exemption, its scope is limited and does not require any evaluation of the environmental performance of the packaging formats themselves. By contrast, Article 29(18)(c) explicitly foresees exemptions where environmental considerations prevent reuse targets from being met. Relying on this provision would require the Commission to assess the available environmental evidence associated with pallet wrappings and straps. In this context, EuPC points to the peer-reviewed life-cycle assessment conducted by IFEU (link: IFEU study) in accordance with ISO 14044 and finalised in April 2025.

…life-cycle assessment conducted by IFEU (link: IFEU study) in accordance with ISO 14044 and finalised in April 2025. The study finds that optimised single-use plastic pallet-wrapping systems perform better than reusable alternatives across key environmental indicators, including climate change. The report also reveals that reusable options require heavier, less adaptable solutions, resulting in increased material consumption and logistical inefficiencies. Similar conclusions are reached in the Deloitte feasibility study( “Study on exclusion of plastic pallet wrappings and straps from the 100% reuse obligations of transport packaging in the PPWR” – Oct 2025), commissioned by the European Ref.

…from the 100% reuse obligations of transport packaging in the PPWR” – Oct 2025), commissioned by the European Ref. Ares(2026)228271 - 09/01/2026 Avenue de Cortenbergh 71 - B-1000 Brussels • Phone: +32 (0)2 732 41 24 • Fax: +32 (0)2 732 42 18 [email protected] • www.plasticsconverters.eu Page 2 of 4 Commission, which identifies higher greenhouse-gas emissions for reuse scenarios, however within a more limited scope which does not include article 29(1). The above environmental considerations allow for Article 29(18)(c) PPWR to be used as a legal basis to exempt pallet wrappings and straps not only from Article 29(2) and (3), but also Article 29(1) PPWR. We call on the European Commission to take this into account and reframe the scope of its Decision.

Article 29(1) PPWR. We call on the European Commission to take this into account and reframe the scope of its Decision. Technical limitations and load safety risks In addition to environmental considerations, EuPC draws attention to significant technical and load-safety constraints linked to reuse obligations for pallet wrappings and straps. Pallet wrapping is essential to ensuring load-unit stability and transport safely throughout palletised supply chains. According to the European Safe Logistics Association (EUMOS), manually applied reusable sleeves examined in the Deloitte feasibility study fail, under normal operating conditions, to meet the EUMOS 40509 load-stability standard when applied to heavy and irregular palletised loads.

…conditions, to meet the EUMOS 40509 load-stability standard when applied to heavy and irregular palletised loads. Automated single-use pallet-wrapping systems, on the other hand, deliver a consistent and verifiable level of load-unit stability that aligns with established safety requirements (more information on EUMOS statement link) Moreover, there are currently no standardised, high-speed, automated reusable pallet-wrapping solutions available at industrial scale that could replace existing single-use systems across sectors. Existing reusable concepts rely either on manual processes or on highly constrained, site-specific logistics arrangements and are incompatible with the automated, high-throughput end-of-line operations widely used in European manufacturing and distribution.

…with the automated, high-throughput end-of-line operations widely used in European manufacturing and distribution. In addition, the Fraunhofer study (April 2025) (link: Fraunhofer study), conducted on behalf of Project Alliance Strapping, shows that straps suffer a loss of strength of 47–60% at the weld point after just one use. The critical issue is that previous damage is not visually detectable. Reuse leads to an incalculable safety risk for load securing. Since physics does not distinguish between different modes of transport, reuse is generally "not recommended" from a technical point of view. A legal quota of 40% would force economic operators to put unsafe loads into circulation, which is unacceptable in terms of liability law. The scientific study therefore concludes that "the reuse of straps for transport packaging and bundling is not technically recommended".

…therefore concludes that "the reuse of straps for transport packaging and bundling is not technically recommended". Additional study findings by Gesellschaft für Verpackungsmarktforschung (link: GVM study) and IFEU (link: IFEU study straps) have confirmed that single use pallet strapping is a preferred option over reuse alternatives in far most cases. With less than 500 gram light-weight pallet strapping already containing over 75% PCR recyclates, loads of over 1.000 kgs can be safely secured on pallets, while the strapping remains fully recyclable after use. These and other studies also predict considerable increase of costs and administrative burden for the entire European industry as a direct consequence of changed logistics potential realities.

…burden for the entire European industry as a direct consequence of changed logistics potential realities. Compounding these issues, the reusable alternatives assessed are not recyclable under current conditions, despite recyclability being a requirement under Article 6 of the PPWR, which raises additional concerns regarding their regulatory suitability. Taken together, these technical, safety and regulatory limitations demonstrate that there are currently no reusable pallet-wrapping solutions at industrial level that are technically mature, compliant and scalable at industrial level.

…pallet-wrapping solutions at industrial level that are technically mature, compliant and scalable at industrial level. Economic consequences and limited practical effect of the exemption Although the draft Delegated Decision removes the obligation to achieve 100% reuse for certain economic operators under Article 29(2) and (3), its overall impact is limited because the most Avenue de Cortenbergh 71 - B-1000 Brussels • Phone: +32 (0)2 732 41 24 • Fax: +32 (0)2 732 42 18 [email protected] • www.plasticsconverters.eu Page 3 of 4 significant economic and operational burdens remain in place under Article 29(1). EuPC is also concerned that the economic impacts cited in the Delegated Decision are significantly underestimated.

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Avenue de Cortenbergh 71 - B-1000 Brussels • Phone: +32 (0)2 732 41 24 • Fax: +32 (0)2 732 42 18 [email protected] • www.plasticsconverters.eu Brussels, 2 January 2021 Ref: Further comments of EuPC 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 in the main questionnaire by European Plastics Converters, EuPC, in addition to the comments below specific questions. Many questions have been written in a biased form. On necessary packaging The questionnaire, in both Sections 2 and 3, makes reference to packaging and the concept of necessity to protect the product or ensure hygiene.

Sections 2 and 3, makes reference to packaging and the concept of necessity to protect the product or ensure hygiene. In this regard, it is important to stress that 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. Moreover, the concept of ‘necessity’ as referred to packaging is not defined in the relevant legislation. On 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, EuPC supports such requirement, although such support is conditional on the reasonability of its implementation.

EuPC supports such requirement, although such support is conditional on the reasonability of its implementation. Not often returnable packaging is the greenest option, as well as imposing recycled content quantity is limited by the availability in the market of the right quantity and quality. On additional measures To increase recyclability (question 15, Section 3), tracer-based sorting technologies are considered as a valid tool, while ensuring a clear distinction between food and non-food grades. Chemical recycling is also another, valid form of disposal, in addition and in a subordinate position to mechanical recycling.

…recycling is also another, valid form of disposal, in addition and in a subordinate position to mechanical recycling. It is important to make decisions on recyclability and best environmental performance with impact assessments (such as LCAs), by prioritising CO2 emissions savings in the use of a type of packaging, harmonise definitions and criteria used at national level (for example through eco-modulation of EPR fees), and consider that the whole recyclability topic is only one facet of a sustainability in Ref. Ares(2021)23732 - 03/01/2021 Avenue de Cortenbergh 71 - B-1000 Brussels • Phone: +32 (0)2 732 41 24 • Fax: +32 (0)2 732 42 18 [email protected] • www.plasticsconverters.eu packaging. Each type of packaging, material or polymer has a legimate reason to exist and provide different characteristics for the expected functionality.

…or polymer has a legimate reason to exist and provide different characteristics for the expected functionality. On COVID19 effects In relation to the COVID-19 impact, this has had opposite effects on the different subsectors of the plastic packaging industry in Europe. 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. The demand for packaging in the medial and hygiene sector has increased as well and is expected to stay on a high level more constantly.

…in the medial 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 applications or the hospitality sector have seen a sharp decline in demand due to the reduced activities of their customers. Here, a return to normality can only stat to take place if the lockdown measures in the Member States are eased and production across the entire industry will resume. Especially in the South of Europe, demand for certain plastic packaging applications also strongly depends on tourism. For the companies active in that field, open borders and restriction-free traveling during the summer holiday period will be crucial for their recovery.

…field, open borders and restriction-free traveling during the summer holiday period will be crucial for their recovery. Overall, when compared to other parts of the plastics converting industry, the plastic packaging sector has suffered the least from the effects of the COVID-19 crisis. For the 2021, the current lack of demand from their customers because of the reduced production in the industry and closure of retail shops and the hospitality sector due to the restrictive measures adopted by the national governments is expected to last also in the first half of 2021. 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.

…the companies have to bear added cost to operate given the additional actions to minimise the contamination potential. While the lockdown measures have slowly started to be eased in some Member States and production has restarted in summer, now the situation remains difficult and there is uncertainty for the coming year. Especially as the predicted economic crisis that will follow the lockdown measures will impact all industrial activities and the packaging industry that supplies them.

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