EuPF welcomes Commission exemption for pallet wrapping and straps, urges science-based consistency under Article 29(1)

Brussels, 16 October 2025

European Plastic Films (EuPF) welcomes the European Commission’s confirmation, made during a recent meeting with stakeholders, of a full exemption for pallet wrapping films and straps from the 100 percent reuse targets set under Articles 29(2) and (3) of the Packaging and Packaging Waste Regulation (PPWR).

The unconditional exemption will be adopted through a delegated act based on Article 29(18)(a), recognising the economic constraints identified in the Deloitte feasibility study. The study highlighted significant investment, logistics and operational costs, including dual end-of-line systems, and found that switching to reusable pallet wrapping would also increase transport emissions.

However, Article 29(1) – which sets 40 percent reuse by 2030 and 70 percent by 2040 for cross-border transport packaging – remains unaddressed. The Commission indicated that it is planning a “pragmatic and realistic” approach to develop the related implementing act under Article 30, which will define the methodology for calculating the reuse targets.

Thomas De Meester, Head of EuPF, said:

“We welcome the Commission’s pragmatic recognition of economic realities under Articles 29(2) and (3). Yet the same scientific and economic evidence clearly shows that an exemption under Article 29(1) is equally warranted. The IFEU life-cycle assessment demonstrates that reusable alternatives lead to significantly higher greenhouse-gas emissions – up to 1700 percent in some applications – while the RDC economic study finds annual cost increases of nearly €5 billion across eight key sectors. From an environmental standpoint, the logic is clear: as transport distances increase, so do emissions, making reuse even less favourable for cross-border logistics and therefore strengthening the case for an exemption under Article 29(1). From an economic and practical perspective, requiring companies to operate parallel palletisation systems for EU and export markets would entail a complete transformation of logistics operations, undermining competitiveness without delivering any environmental benefit.”

EuPF continues to advocate for a science-based and coherent implementation of the PPWR, ensuring that reuse obligations genuinely reduce environmental impact while maintaining Europe’s competitiveness and operational efficiency. Any future solutions must also maintain current standards of load stability and worker safety, achieved through years of technical optimisation and investment.

The association continues to advocate for an exemption for pallet wrapping and straps under Article 29(1), without impeding the progress already achieved on Articles 29(2) and (3). In parallel, EuPF will engage constructively in the development of the Article 30 Implementing Act to ensure it remains realistic, evidence-based and aligned with industrial practice.

About EuPF
​The European Plastic Films (EuPF) sector group within EuPC represents Europe’s plastic-film converting industry. EuPF promotes a sustainable, innovative and competitive future for Europe’s flexible plastic packaging sector by working with policymakers, value-chain partners and researchers to ensure that legislation supports real circularity and resource efficiency.

Contact
​Thomas De Meester – Head of EuPF
​E-mail: thomas.de.meester@eupc.org
​Website: www.europeanplasticfilms.eu