Industry reaction to the Commission’s Delegated Act under Article 29 PPWR
EUROPEN (The European Organisation for Packaging and the Environment) has prepared a joint industry position on Article 29(1). PPWR, which was forwarded to the European Commission (President Von der Leyen and Commissioners Roswall, Dombrovskis, Séjourné, and Ribera), as well as to representatives of Member States and relevant Members of the European Parliament.
EUROPEN points out that the Commission’s decision to introduce a derogation for pallet wrappings and straps from the 100% reuse targets set out in Article 29(2) and (3) of the Packaging and Packaging Waste Regulation (PPWR) represents a welcome recognition of the operational challenges consistently raised by the European packaging value chain throughout the legislative process. By acknowledging these practical constraints, the Commission affirms the evidence provided by businesses across sectors, demonstrating that these packaging formats are not suitable for reuse and that, to date, no proven reusable alternatives exist at scale that can guarantee an equivalent level of load stability, product protection, transport safety, and operational reliability. Therefore, the decision to restrict this derogation exclusively to the 100% target, leaving the 40% reuse target of Article 29(1) untouched, is both inconsistent and disappointing.
EU Leaders have committed to simplification, enhanced competitiveness, and a regulatory framework that reinforces its industrial base. Granting a targeted exemption from the 40% reuse target for specific transport packaging formats, prioritising recyclability or recycled content where reuse is technically unsuitable, is essential to delivering on these commitments in a coherent and practical manner.
A fragmented approach would lead to a framework that is difficult to apply consistently, raises questions around legal certainty and proportionality, and creates real implementation challenges for companies. We therefore call on the Commission to prioritise the swift adoption of a delegated act exempting pallet wrappings and straps, as well as comparable transport packaging solutions, from the 40% reuse target under Article 29(1), in accordance with Article 29(18)(a) to (c). This is a necessary step to ensure that the PPWR remains workable, proportionate, and fit for purpose.
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