Film on a roll is not yet packaging

PRESS RELEASE ​ ​ ​ ​ Brussels, 19 August 2026

A new example in the Commission’s FAQ treats stretch film as packaging while it is still on the roll. It does not align with the definitions and purpose of the new Packaging Regulation, nor with the position of 16 national packaging registers, and with the way responsibility is organised in practice today.

European Plastic Films (EuPF), the sector group of European Plastics Converters representing Europe’s film producers, calls on the European Commission to withdraw and replace an example in the second edition of its Frequently Asked Questions on the Packaging and Packaging Waste Regulation (PPWR), published on 1 August 2026. The example states that stretch film is packaging already when it is sold on a roll, and that the responsible manufacturer is the film producer rather than the company that wraps the pallet.

EuPF believes that reading should be reconsidered, and that the same reasoning extends beyond stretch film to other flexible transport packaging materials supplied on a roll or in strand form. Film delivered on a roll is a packaging material. It becomes packaging at the moment it is applied to a load. Now that the Regulation has entered into application, on 12 August 2026, this clarification should be made without delay.

“A roll of film is raw material for a packaging operation, not a finished packaging. It has running metres, width and thickness, but its size and shape as packaging are set by the customer who orders and designs the load unit, not by the film producer. The company that decides how the load is secured is the company that creates the packaging. That is not a matter of opinion, it is what the PPWR says, and it is what the national registers have already published.”

Thomas De Meester, Head of EuPF

The wrapping operator decides the packaging format

The PPWR defines packaging by two conditions that must both be met: the item must serve a packaging function, and it must be possible to distinguish it by its packaging format, i.e. the size and shape of a specific packaging unit. Size and shape — and other technical characteristics such as resistance, elasticity and PCR content — are decided by the customer that orders the packaging, created at the wrapping station and determined by the dimensions of the load, the number of layers and the pre-stretch ratio.

The legislator has already settled a comparable case. Annex I of the PPWR lists wrapping paper sold separately to business operators as an example of a non-packaging item. Film supplied on a roll to a business customer is the same situation, and the definition of packaging is material-neutral: paper and plastic cannot be classified differently. Annex I also treats the roll core as the packaging and the wound film as the product inside it — which only makes sense if the film is not itself the finished packaging.

This is also why the PPWR creates a distinct, lighter set of duties for those who supply packaging material rather than place the finished packaging on the market: Article 16, headed “Information obligations of suppliers of packaging or packaging materials,” provides for exactly this situation. Film on a roll is the clearest example of that category.

The FAQ also appears inconsistent on this point. A few lines above the example, it states that packaging is in its final form only when it can be used as transport packaging without further components. Film on a roll cannot because it is added to the loaded pallet. And for unbranded packaging the FAQ asks who decides the design specifications — gauge, pre-stretch ratio, number of layers and wrapping pattern are all decided by the operator that wraps, not by the film producer.

The interpretation undermines the Regulation’s own objectives

An important and unfortunate consequence of the Commission’s interpretation is that the film producer, if treated as manufacturer, cannot meet all the obligations that role carries under the PPWR. This is particularly true of the detailed requirements on packaging minimisation in Article 10: an exemption would need to be introduced for film producers, since they do not control the gauge, pre-stretch ratio or number of layers that determine minimisation, just as they do not control the size and shape of the packaging itself. The shift of responsibility would also weaken the Regulation’s effect on minimisation, since the economic operator who actually decides how much film is used on each load would bear no responsibility for that choice. Article 24 on excessive packaging would not compensate for this, because overuse of stretch film is not a question of empty space ratio. These effects sit awkwardly with packaging waste prevention, one of the PPWR’s central objectives.

The interpretation would also affect the recyclability of stretch film. As manufacturer, the film producer would be expected to meet the recyclability design requirements that role carries, yet it has no control over the labels and labelling adhesives applied to the film once it is on the pallet, both of which materially affect recyclability, as recognised in the standards developed for PE and PP flexible packaging under standardisation request M/584 on plastics recycling and recycled plastics.

The national registers have taken the opposite view

On 25 June 2026 the registers and competent authorities of 16 Member States, organised in the European Network of Packaging Registers (EUNR), published a joint explanation of who the responsible producer is. For films it is unambiguous: where packaging takes its final form only at filling, the supply chain begins with the filling. The same paper describes stretch, shrink and cling film expressly as packaging materials. The Commission’s example therefore conflicts with the bodies that run registration, reporting and enforcement in the Member States. In practice, the extended producer responsibility fee for pallet stretch film is invoiced today in nearly all Member States to the company that wraps the pallet, not to the film producer.

Multiplication of producers for one transport packaging unit

The FAQ is not legally binding. However, where responsibility is unclear, companies do not wait — they protect themselves. If the FAQs are not corrected, film producers named as manufacturers by the Commission will register and apply for authorisation in every Member State they supply. The same holds true for makers of other transport packaging material supplied on a roll or in strand form, e.g. shrink film and shrink hoods, adhesive and bundling tape, strapping, edge and corner protectors, interlayers and slip sheets, netting and void fill, and flat corrugated blanks. Wrapping operators, told by their own national register that they remain responsible, cannot drop the individual packaging components from their declaration that already covers the entire loaded and secured pallet. The results are multiple registrations, applications for authorisation, sets of tonnage reports and, in many cases, multiple fees on the same packaging component.

Enforcement suffers in the same way. The film on a wrapped pallet carries no marking, the producer cannot allocate its output by Member State, and the declarations are measured on different bases and cannot be reconciled. The measure is presented as simplification because there are fewer film producers than film users. In practice it adds a registered producer to each supply chain for a material that is declared once today.

EuPF’s recommendations

EuPF supports the objectives of the PPWR and is ready to work with the Commission on the technical side of pallet stabilisation, including application data on pre-stretch ratios, gauge reduction and layer optimisation.

No change for customers in the meantime

Nothing changes in the cooperation between film producers and their customers. Film producers continue to supply the information and documentation their customers need for their own compliance records, as Article 16 requires of suppliers of packaging materials. If the FAQ wording remains unchanged, EuPF will approach the value chain immediately to agree how the necessary evidence is shared along the supply chain.

Press contact

Thomas De Meester, Head of EuPF
​thomas.de.meester@eupc.org ​
​EuPC, Avenue de Cortenbergh 71, 1000 Brussels, Belgium