VDMA e.V.

VDMA e.V. Lyoner Str. 18 60528 Frankfurt am Main, Germany Phone +49 69 6603-1907 E-mail [email protected] Internet www.vdma.org Register of Associations AG Frankfurt/Main, No. VR4278 Registration number: R000802 Environmental Affairs and Sustainability Head of Department: Dr Sarah Brückner Machinery and Equipment Manufacturers Association President: Karl Haeusgen Executive Director: Thilo Brodtmann VDMA position paper Proposal for a Regulation on packaging and packaging waste With this position, VDMA, the Machinery and Equipment Manufacturers Association, is commenting on the most important aspects of the proposal for for a Regulation on packaging and packaging waste (EU Packaging Regulation). The VDMA welcomes the objectives of the proposed EU Packaging Regulation and the change from a directive to a regulation.

VDMA welcomes the objectives of the proposed EU Packaging Regulation and the change from a directive to a regulation. EU-wide harmonised and thus uniform packaging law requirements contribute significantly to a sustainable circular economy and the efficient functioning of the EU internal market. The new EU Packaging Regulation can thus replace the current "patchwork" of specific packaging regulations in the EU Member States. In order not to jeopardise the objectives of the new EU Packaging Regulation and to ensure the functioning of the EU internal market with regard to packaging law requirements, the EU Commission should ensure that no further individual national measures with regard to packaging law regulations are implemented in the EU Member States.

…further individual national measures with regard to packaging law regulations are implemented in the EU Member States. The EU Commission should also work to ensure that existing national packaging regulations that undermine the EU internal market are repealed. It must be ensured that the new requirements of the EU Packaging Regulation are implemented quickly, completely and verifiably in all EU Member States. This is the only way to achieve EU-wide harmonisation in the area of packaging law requirements and to prevent competitive disadvantages. Mechanical and plant engineering as enabler of the circular economy In the view of the mechanical and plant engineering industry, climate neutrality is only possible with a future-oriented and efficient circular economy.

…plant engineering industry, climate neutrality is only possible with a future-oriented and efficient circular economy. With its innovative technical solutions, mechanical and plant engineering makes a significant contribution to reducing CO2 emissions and avoiding food and packaging waste. In this context, the discussions of recent years have focused primarily on the topic of plastics. This has led to extensive new regulations (EU Single-Use Plastic Directive). The sustainable use of plastics requires a functioning circular economy and the careful use of resources1 . As an enabler of the circular economy, the mechanical and plant engineering sector sees more opportunities than risks in the EU Packaging Regulation and offers itself as a transparent and open discussion partner to all stakeholders for in-depth discussions. The following points can be used as a basis for the discussions.

…partner to all stakeholders for in-depth discussions. The following points can be used as a basis for the discussions. It must be taken into account that individual articles of the proposed regulation allow for a wide margin of interpretation. The unclear requirements inevitably lead to uncertainty and thus to planning insecurities for all affected market actors; they also cause costs and hinder and prevent future sustainable innovations. 1 VDMA Discussion paper: Sustainable use of plastics pro Circular Economy! Ref. Ares(2023)2868512 - 24/04/2023 2 VDMA e.V. Lyoner Str. 18 60528 Frankfurt am Main, Germany Phone +49 69 6603-1907 E-mail [email protected] Internet www.vdma.org Register of Associations AG Frankfurt/Main, No.

+49 69 6603-1907 E-mail [email protected] Internet www.vdma.org Register of Associations AG Frankfurt/Main, No. VR4278 Registration number: R000802 Environmental Affairs and Sustainability Head of Department: Dr Sarah Brückner Machinery and Equipment Manufacturers Association President: Karl Haeusgen Executive Director: Thilo Brodtmann On the proposal for an EU Packaging Regulation in detail: Article 5 - Requirements for substances in packaging According to Article 5(1) of the proposed EU Packaging Regulation, packaging shall be manufactured in such a way as to minimise the presence and concentration of substances of concern as constituents of the packaging material or any of the packaging components. Discussions on the topic “substances of concern” are currently underway and must be seen in the context of the revision of the EU chemicals regulation REACH.

…concern” are currently underway and must be seen in the context of the revision of the EU chemicals regulation REACH. Against this background, VDMA believes it is premature to include regulations on substances of concern in the EU Packaging Regulation. Consistency and coherence with the EU chemicals regulation REACH must be ensured. Article 6 - Recyclable packaging "Design for recycling" criteria must be given high priority in the proposed EU Packaging Regulation and in the delegated acts. Only if recycling is considered from the beginning can correspondingly high recycling rates be achieved at the end of life. The mechanical and plant engineering industry therefore welcomes the assessment of the recyclability of packaging on the basis of uniform EU-wide "Design for recycling" criteria.

…the assessment of the recyclability of packaging on the basis of uniform EU-wide "Design for recycling" criteria. In the EU, there are already numerous guidelines on the topic of "Design for Recycling" for both plastic and fibre-based packaging (see Annex). These should be incorporated into a uniform catalogue of criteria. Attention must be paid to ensuring that these criteria and the disposal and recycling options, which are currently still very different in the EU member states, are compatible with each other by law. Before criteria are set on the basis of delegated acts, stakeholders from the entire packaging value chain should be consulted. The VDMA would therefore advocate the formation of an independent expert group with stakeholders from the entire packaging value chain to support the EU Commission in the development of these criteria.

…stakeholders from the entire packaging value chain to support the EU Commission in the development of these criteria. Article 7 - Minimum recycled content in plastic packaging VDMA generally welcomes the definition of minimum recycled content in plastic packaging. In recent years, the use of recycled material, some of which is costly to produce, has failed due to reservations on the part of users and, above all, time and again due to the lack of price parity between primary and secondary plastics. This obstacle should be removed with the minimum percentage of recycled material per packaging unit obtained from post-consumer plastic waste provided for in Article 7 of the EU Packaging Regulation.

…per packaging unit obtained from post-consumer plastic waste provided for in Article 7 of the EU Packaging Regulation. However, the mechanical and plant engineering industry expressly appeals that the design of the quotas should be gradual and dynamic, starting from simple applications outside food packaging where standard plastics (PE, PP, PET, PS and PVC) are used. 3 VDMA e.V. Lyoner Str. 18 60528 Frankfurt am Main, Germany Phone +49 69 6603-1907 E-mail [email protected] Internet www.vdma.org Register of Associations AG Frankfurt/Main, No.

+49 69 6603-1907 E-mail [email protected] Internet www.vdma.org Register of Associations AG Frankfurt/Main, No. VR4278 Registration number: R000802 Environmental Affairs and Sustainability Head of Department: Dr Sarah Brückner Machinery and Equipment Manufacturers Association President: Karl Haeusgen Executive Director: Thilo Brodtmann From a technical point of view, VDMA is critical of the mandatory use of recycled content for contact-sensitive packaging. The prerequisite for use in this area is suitable, i.e. approved recycling technologies. Here, the industry still sees a considerable need for action and, above all, innovation in order to be able to realise the ambitious goals of the minimum share of recycled content.

…and, above all, innovation in order to be able to realise the ambitious goals of the minimum share of recycled content. According to section 2 of Regulation (EU) 2022/16162 , "A pre-requisite to any increase in recycled content in food packaging and other food contact materials remains the need to secure a high level of protection of human health.

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E N V I R O N M E N T A N D S U S T A I N A B I L I T Y P O S I T I O N P A P E R Draft delegated decision of the EU Commis- sion supplementing Regulation (EU) 2025/40 of the European Parliament and of the Council by exempting certain economic operators that use pallet wrappings and straps from the 100% reuse requirements of these packaging for- mats EU Transparency Register ID: 9765362691-45 Ref. Ares(2026)233490 - 09/01/2026 2 Introduction and background Paragraphs 2 and 3 of Article 29 of the PPWR stipulate reuse rates of 100% for many types of industrial and commercial transport and sales packaging from 2030 onwards. Article 29(1) of the PPWR stipulates a 40% reuse rate for these transport and sales packaging items for cross-bor- der transport between independent companies within the territory of the EU from 2030 onwards.

…items for cross-bor- der transport between independent companies within the territory of the EU from 2030 onwards. These requirements also apply to pallet wrapping and straps used to stabilise and protect prod- ucts transported on pallets. On 10 December 2025, the European Commission published a proposal for a delegated deci- sion1 pursuant to Article 29(18) of the PPWR. This proposal provides for economic operators who use pallet wrapping and straps in the cases referred to in Articles 29(2) and (3) PPWR to be exempted from the obligation to reuse them in full from 2030 onwards. The proposal follows an announcement by the European Commission in April 2024. The VDMA expressly welcomes the exemption (delegated act) now proposed by the EU Com- mission for the 100% reuse requirements for pallet wrapping and straps.

(delegated act) now proposed by the EU Com- mission for the 100% reuse requirements for pallet wrapping and straps. However, the dele- gated decision now presented does not include an exemption from the 40% reuse requirements under Article 29(1) PPWR. From the perspective of the VDMA and many other stakeholders, there is also an urgent need for action with regard to this quota in terms of creating a legally de- fined exemption within the framework of the proposed decision. The VDMA demands Pallet wrappings in the form of stretch/shrink films and hoods as well as straps are indispensa- ble for the stable fixation and securing of load units (such as pallets, cartons, etc.) during transport. They securely enclose the load, protect it from environmental influences and damage, and prevent it from slipping and tipping during transport.

…load, protect it from environmental influences and damage, and prevent it from slipping and tipping during transport. The aspect of load and transport safety is not taken into account in the PPWR. Load securing is of utmost importance for road safety. Products stacked on pallets and packed in transport packaging must be secured in such a way that they can withstand all stresses dur- ing transport. Inadequate or incorrect securing of loaded pallets increases the risk of transport damage. In addition to damage to the packaged products themselves, damage to the transport vehicle and even personal injury may occur.

…to damage to the packaged products themselves, damage to the transport vehicle and even personal injury may occur. 1 Packaging and Packaging Waste – exemptions from the reuse obligations for plastic wrappings and straps (delegated act) 3 According to recital 17 of EU Directive 2014/47/EU2, all parties involved in a logistics process, such as packers, shippers, etc., must ensure that the load is properly packed. Wrapping and/or strapping loaded pallets increases safety during transport and minimises the risk of consequen- tial damage. Products packed on pallets that are secured appropriately can also be placed side by side in the transport vehicle in a simple and space-saving manner, which contributes to bet- ter utilisation of the loading space and thus saves costs. Numerous studies show that there are no equivalent reusable alternatives to single-use plastic pallet wrappings and straps.

…studies show that there are no equivalent reusable alternatives to single-use plastic pallet wrappings and straps. The JRC study ‘Plastic pallet wrappings and straps’ commissioned by the European Commis- sion confirms that reusable alternatives to pallet wrappings and straps, such as nets or tarpau- lins, only guarantee sufficient stability for uniformly designed profile A loads (e.g. palletised boxes of the same size). In the case of irregular loads (profile B/C), which are very common in the B2B sector, load security cannot be guaranteed. The study ‘The environmental relevance of selected parameters of single-use and reusable transport packaging’3 by the Institute for Energy and Environmental Research Heidelberg (ifeu) highlights the considerable weaknesses in the transport safety of reusable load systems com- pared to stretch film and strapping bands.

…weaknesses in the transport safety of reusable load systems com- pared to stretch film and strapping bands. The Fraunhofer IMWS study ‘Analysis of the damage behaviour of strapping tapes under differ- ent load cases’4 from April 2025 shows that the breaking strength of welded joints in plastic strapping tapes (PP/PET) decreases by an average of 47 to 60 percent after just one use. Ther- mal stresses caused by temperature fluctuations between +40 and -30 degrees Celsius lead to additional tension in the strapping. This weakens the material during use. The critical factor here is that such pre-existing damage is not visually detectable. Reuse therefore leads to an incalcu- lable safety risk when securing loads. A study by Gesellschaft für Verpackungsmarktforschung mbH (GVM)5 clearly shows the limita- tions of current reusable alternatives to straps.

…für Verpackungsmarktforschung mbH (GVM)5 clearly shows the limita- tions of current reusable alternatives to straps. The straps with clips examined in the study ex- hibit significant weaknesses in terms of tensile strength and elasticity, which are of central im- portance for load securing. All studies therefore conclude that a reuse rate of 40% is not technically feasible with the cur- rently available reusable alternatives to stretch film and straps. 2 EUR-Lex - 02014L0047-20220927 - EN - EUR-Lex 3 Report Challenges Reuse Targets for Strapping: Recycling May Be the Greener Path 4 EUMOS Statement on Art. 29 (1-3) of the Packaging and Packaging Waste Regulation (PPWR) - EU- MOS 5 EUMOS Statement on Art.

Statement on Art. 29 (1-3) of the Packaging and Packaging Waste Regulation (PPWR) - EU- MOS 5 EUMOS Statement on Art. 29 (1-3) of the Packaging and Packaging Waste Regulation (PPWR) - EU- MOS 4 A comparative life cycle analysis6 by the ifeu Institute showed that reuse is not the more ecologi- cal solution for pallet wrapping. Reusable systems cause a higher environmental impact, require more resources and are less logistically efficient than advanced single-use plastic alternatives. The study, which was presented in April 2025 and is based on a robust life cycle assessment (LCA) methodology in accordance with ISO 14040 and 14044 standards, concludes that single- use pallet wrappings are advantageous over reusable, provided that they contain at least 35 per cent post-consumer recycled content, as required by Article 7(1)(d) of the PPWR from 2030 on- wards.

…at least 35 per cent post-consumer recycled content, as required by Article 7(1)(d) of the PPWR from 2030 on- wards. The study concludes that blanket reuse requirements should be avoided. Despite being single-use items, disposable straps and pallet wrappings often have a better car- bon footprint than reusable alternatives. They are collected and sent for appropriate profes- sional recycling. In many EU Member States, stretch film for pallet wrapping achieves higher re- cycling rates than household packaging, supported by established closed-loop systems be- tween logistics and recycling companies. Recycled material is already increasingly being used to manufacture PET strapping. This saves approximately 85 per cent in CO2 emissions com- pared to the use of primary material.

PET strapping. This saves approximately 85 per cent in CO2 emissions com- pared to the use of primary material. Compared to the use of new granulate, this means a sav- ing of approximately 2.5 tonnes of CO2 per tonne of material produced. Straps are a resource- saving packaging material due to their low material usage, low weight and good recyclability. This is particularly true when they are made from 100% recycled material (PCR), which is in- creasingly the case today. Mechanical and plant engineering is a highly export-oriented industry7. 43 per cent of exports go to the EU-27 countries, 13 per cent to other European countries. The share of deliveries to countries outside Europe is 44 per cent. With a share of 21 per cent, Asia is the second most important sales region, followed by North America with 15 per cent.

…a share of 21 per cent, Asia is the second most important sales region, followed by North America with 15 per cent. If the 40% reuse rate were to be maintained, companies would be forced to set up parallel pack- aging lines for pallet securing in order to distinguish between disposable packaging for export and reusable packaging for internal EU traffic. Companies would be forced to invest in systems that are neither environmentally friendly nor technically reliable and, moreover, create consider- able occupational safety risks by foregoing automation. This also entails a considerable admin- istrative burden for companies. Furthermore, competitiveness, especially vis-à-vis non-Euro- pean market participants, would be severely impaired. In her letter dated 19 May 2025, Jessika Roswall responds to a letter from the IK Industriever- einigung Kunststoffverpackungen e.V.

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