The undersigned associations representing different segments of the packaging value chain, urge policy makers to agree on effective and realistic measures for transport packaging during the trilogue negotiations on the Packaging and Packaging Waste Regulation (PPWR). Such measures should take into account the real impact that reuse obligations have on certain packaging formats and related products.

While we recognise that reuse has a role to play in accelerating packaging circularity, derogations should apply where the reusability of packaging does not provide the best overall environmental outcome or when reuse is not a viable option due to the specific requirements of the products packed, the impact on packaging performances and consequently, transport and food safety.

Flexible transport packaging formats including intermediate bulk containers, pallet wrappings, shrink wraps and stretch films are specifically intended to provide load stability thus securing the cargo and preventing potential accidents and damage. Pallet wrappings allow for the unitisation of goods, turning multiple items into a single, manageable load. This allows efficient handling during loading, unloading, and storage, reducing the time and work required for these processes.

Flexible formats also serve as a protective barrier against external elements, crucial to maintain hygiene standards for packaging in contact with food, food ingredients or products that may be sensible to moisture or contamination. This holds true also for insulation transport packaging which is primarily used for transporting medicines/vaccines, pharmaceuticals or food over long distances while maintaining the cold chain.

Furthermore, protective packaging for fragile or heavy items, such as home appliances is customised to offer specific shock-absorbing protection. This tailored protection is designed to match the unique shape and size of each product type further safeguarding against potential harm or damage.

The above-mentioned packaging formats are also easily collected and highly recyclable and can be manufactured with significant percentages of recycled plastics, thereby having a positive impact on increasing recycling rates, and any regrettable substitution should be assessed when setting minimum requirements in relation to recycling at scale.

The characteristics and performances of protective and flexible transport packaging formats cannot be guaranteed through reuse. For example, the cushioning or stretching properties of the material would diminish with each use, compromising the protection afforded to the packaged items and transport safety requirements. Very limited reuse alternatives are available in Europe which have not demonstrated the same performances of these packaging formats neither in terms of efficiency and safety nor from a life cycle perspective.

We urge policy makers to consider the unique requirements of these packaging formats when defining reuse obligations for transport packaging to prevent that disproportionate or unfeasible targets would lead to supply chains’ disruptions, negatively impacting the efficiency of transporting goods and of businesses dependent on reliable and safe logistics.

Furthermore, as the development of reuse systems and reverse logistics require significant investments and reorganisation of processes and supply chains, all reuse obligations, including those set out in paragraph 12 and 13 of Article 26, should apply from 2030, to allow companies the necessary time to build and implement these systems.

We therefore call on the co-legislators to consider the following recommendations, to ensure a balanced approach that promotes packaging circularity without compromising transport safety.