Knauf Insulation

Knauf Insulation Avenue Cortenbergh 120, 1000 Brussels, Belgium| www.knauf.com EU Transparency Register number: 971446611568-25 Classified as Internal and General Business Knauf Insulation Position on the Packaging and Packaging Waste Regulation Consultation on Draft Delegated Decision Packaging and packaging waste represents an increasing problem with more and more waste being generated in the EU. Over the last decade, waste grew nearly by 25% and a total amount of almost 80 million tonnes of packaging waste was generated in the EU in 2023. To address the growing problem and align our packaging and packaging waste with the goals of the Green Deal, the European Commission rightly revised the rules on Packaging and Packaging Waste with the recently adopted Packaging and Packaging Waste Regulation (EU) 2025/40. The Regulation sets down requirements to adapt our packaging to improve…

…sets down requirements to adapt our packaging to improve sustainability considerations and prevent waste generation. 1. Circular packaging ambitions As a company, Knauf Insulation has embraced sustainable and circular solutions also for the packaging of its products. We are delivering on our packaging sustainability ambitions and consistently raise the bar with increasingly ambitious standards. Until 2032, our sustainability goal includes that we overall want to use less materials and produce less waste. As regards our packaging, we want to use at least 35% recycled content in our plastic packaging. Furthermore, we aim for at least 80% of our plastic packaging to be recyclable by 2032. The packaging of our products presents a crucial part of our manufacturing as it allows us to deliver our products safely to our customers.

…products presents a crucial part of our manufacturing as it allows us to deliver our products safely to our customers. Within our production, the packaging is added in an automated fashion through so-called stretch hoods, before the product encased in the plastic is placed on the pallet for delivery. Stretch hoods are elastic elements, allowing us to adapt the packaging of the demanded product volume, while at the same time also providing secure, waterproof containment for transport. Our sites specifically use a compression technology to allow us to adapt the packaging to larger delivery loads per cubic meter.

…specifically use a compression technology to allow us to adapt the packaging to larger delivery loads per cubic meter. This allows us not only to improve the storage and efficient packaging of the demanded product for the customer but also has the added benefit that it helps us reduce additional miles for trucks, which in turn significantly allows us to decrease our scope 3 emissions through reduced transport emissions and fuel use. Next to providing superior load stability, stretch films are also easily recyclable, presenting a circular option in and of itself. Pallet wrappings and straps are essential tools in ensuring that our products remain safe and stable throughout the transport until they reach their destination.

…tools in ensuring that our products remain safe and stable throughout the transport until they reach their destination. 2. Safe handling and transportation While we invest in continuous improvement and the inclusion of circular solutions for both our products and packaging, the safe handling and transportation along the entire value chain for our product is paramount. Over the past we’ve incorporated increased recycled content in the packaging and aim to do so at an increased rate in the future. The introduction of a complete re-use system, however, risks not fulfilling the same safety aspects as the currently conventional solutions offer. Manually applied reusable options for instance, do not offer the same load security and would thus present a safety risk in the supply chain. We therefore welcome the proposed exemptions for pallet wrappings and straps from the 100% reuse obligations…

…competitiveness is a stated goal of the European Commission’s Competitiveness Compass and the Clean Industrial Deal. 3. Future-proofing our packaging to safeguard competitiveness Packaging provides a crucial part to our manufacturing process by ensuring our products arrive safe and sound at our customers doorstep. While the exemption of obligations of Art. 29 (2) and (3) are welcomed, additional adjustments Ref. Ares(2026)222049 - 09/01/2026 Classified as Internal and General Business ought to be considered for obligations enshrined in Art. 29(1) relating to reuse targets for cross-border transport. Art. 29(1) sets up reuse targets for 2030 (40%) and for 2040 (70%) for transport packaging in cross-border operations. Not only are reusable alternatives lacking in terms of load safety but also cause increased costs and transport emissions.

…only are reusable alternatives lacking in terms of load safety but also cause increased costs and transport emissions. Increasing the sustainability of packaging by advancing the circularity potential, i.e. recycled content of packaging, provides a better, more sustainable and future proof alternative. Moreover, to ensure that packaging is future-proof, respects realistic market conditions and upholds safety requirements, it is crucial that all relevant categories for exemption are taken into consideration. Art. 29(18) lays out the conditions for exemption and rightly contains e.g. economic constraints and environmental issues. While these two conditions for exemption are crucial, they should be complemented by safety considerations to ensure load unit security and transport safety are equally taken into consideration. 4.

…by safety considerations to ensure load unit security and transport safety are equally taken into consideration. 4. Paving the Way for Circular Market Practices As a company that is highly dependent on packaging material to transport and deliver our products safely to our customers, we place great value in high-quality packaging. At the same time, we are committed as a company to do our part and advance on the green transition. This begins with decarbonising our manufacturing process and clearly extends to our packaging. We wholeheartedly subscribe to the goals of the upcoming Circular Economy Act and would like to see increased circular practices enter the construction market. As a part of that we have committed to reducing virgin plastic film packaging and where possible to take back between 25-50% of plastic film packaging from our customers for recycling.

…packaging and where possible to take back between 25-50% of plastic film packaging from our customers for recycling. Reducing virgin plastic use is a commitment of Knauf Insulation’s circular economy journey: using 30% of recycled plastic material in our packaging can help us to decrease by 25% the carbon footprint of the plastic packaging. In the future, we aim to increase the recycled content of plastic packaging even further to ensure that packaging needs equally fulfil sustainability and safety considerations. As industry adapts and introduces circular solutions, we welcome the proposed considerations for exemption for pallet wrappings and straps from the 100% reuse obligations and the European Commission’s consideration of pragmatic realities of businesses implementing the PPWR on the ground.

…and the European Commission’s consideration of pragmatic realities of businesses implementing the PPWR on the ground. As the PPWR enters implementation and additional deadlines come into play, we urge policymakers to consider market practicalities to allow packaging to be future-proof, safe and sustainable, while supporting the competitiveness of European industry. Classified as Internal and General Business WHO WE ARE Knauf is one of the world’s largest manufacturers of modern construction products and systems with over 300 plants in more than 90 countries and over 40,000 employees worldwide. Our annual turnover is approximately €15.6 billion (in 2024). We are 100% independent and family owned. Part of the Knauf Group, Knauf Insulation has more than 40 years of experience in the insulation industry and is one of the fastest growing and most respected names in insulation worldwide.

…in the insulation industry and is one of the fastest growing and most respected names in insulation worldwide. We are committed to help our customers meet the increasing demand for energy efficiency and sustainability in new and existing homes, non-residential buildings and industrial applications.

…energy efficiency and sustainability in new and existing homes, non-residential buildings and industrial applications. OUR CONTACT DETAILS Shiraz Dromi Zernitsky – Group Public Affairs Director EMEA/APAC Email: [email protected] Maira Madala – EU Public Affairs Manager Email: [email protected] EU Transparency Register number: 971446611568-25 www.knauf.com OUR ASSOCIATIONS - We are members of the following EU associations and campaigns and fully support their positions: EURIMA (European Insulation Manufacturers Association), Eurogypsum, EU-ASE (European Alliance to Save Energy), World Green Building Council – European Regional Network, EBE (Efficient Buildings Europe), Renovate Europe campaign, Fire Safe Europe (FSEU) and the World Green Infrastructure Network (WGIN).

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