In a rare display of total industry alignment, over 60 European trade associations have issued a joint statement regarding the European Commission’s latest Delegated Act under the Packaging and Packaging Waste Regulation (PPWR).
TABLE OF CONTENTS
While the Commission’s move on February 25, 2026, to exempt pallet wraps and straps from 100% reuse targets (PPWR Article 29(2) and 29(3)) is a critical step, a significant obstacle remains. The industry warns that maintaining a 40% mandate for the same materials under Article 29(1) creates a dangerous regulatory inconsistency that threatens both supply chain safety and economic competitiveness.
The Technical Impossibility of Reusable Stretch Film
The core of the industry’s concern lies in material performance. Pallet wrapping films and strapping tapes are the primary load-securing tools of global logistics. They are engineered to provide maximum tension and structural integrity.
Once a pallet wrap is cut at its destination, it immediately loses its functional capacity. Unlike a plastic crate or a wooden pallet, which can be washed and reused, a cut film is technically waste. The joint statement highlights that, as of early 2026, no proven reusable alternatives exist at scale that can guarantee the same level of load stability, product integrity as well as worker safety.
The Economic and Environmental Paradox
Beyond the technical difficulties, the financial implications are also staggering. Independent studies commissioned by the European Plastics Converters (EuPC) estimate that enforcing mandatory reuse for pallet packaging could impose an additional €4.9 billion in annual costs across key sectors, including retail and beverages. These costs stem from the need for dual packaging lines, expensive return logistics and specialized cleaning infrastructure.
Moreover, there is a significant environmental paradox. While “reuse” sounds sustainable, the specialized logistics required to return, wash and redistribute heavy-duty reusable pallet covers can actually increase CO2 emissions. The same studies mention that the carbon footprint of a mandatory reuse system for stretch film was found to be up to 1700 % higher than high-efficiency, recyclable single-use alternatives.

A Fragmented Approach to the Circular Economy
By acknowledging that these formats are unsuitable for 100 % reuse, the Commission has effectively admitted the technical limitations of the material. Yet, leaving the 40 % reuse target untouched creates a fragmented regulatory framework. For a manufacturer, a 40 % target for a non-reusable material is just as unachievable as a 100 % target; it simply introduces legal uncertainty.
The Call for Science-Based Consistency
The associations, representing a broad alliance of the plastics, paper, glass, chemical and consumer goods industries, are calling for a swift adoption of a Delegated Act that exempts pallet wraps, straps and comparable transport solutions from the 40 % target as well.
The industry is not asking for a pass on sustainability. The regulation should prioritize:
- High-Level Recyclability: Ensuring 100 % of film is captured via closed-loop collection.
- Increased Recycled Content: Mandating the use of post-consumer recyclate (PCR) in new films.
- Material Reduction: Using advanced pre-stretch technologies to minimize the weight of film needed per pallet.
Conclusion
For the PPWR to remain a successful pillar of the European Green Deal, it must reflect the operational realities of the European supply chain. Turning packaging design into a matter of unmanageable financial and safety risk serves neither the environment nor the economy.
Therefore, the industry awaits a response that prioritizes scientific evidence and logistical safety over arbitrary percentage thresholds. Ensuring a workable, proportionate framework is the only way to safeguard European competitiveness while achieving true circularity.








