The signatories welcome the Commission’s decision to introduce a derogation for pallet wrappings and straps from the 100% reuse targets defined in Article 29(2) and (3). According to the statement, this move reflects a growing recognition of the operational challenges consistently raised by stakeholders across the European packaging value chain. Industry representatives have long argued that these transport packaging formats are not suitable for reuse and that no scalable alternatives currently exist that can ensure comparable levels of load stability, product protection, transport safety, and operational reliability.

At the same time, the joint statement highlights a key inconsistency. While exempting pallet wrappings and straps from the 100% reuse targets, the Commission maintains the 40% reuse target under Article 29(1) for the same applications. According to EDANA and its co-signatories, the technical and safety limitations apply equally in both cases.

Pallet wrapping films, for example, lose their structural integrity once cut upon delivery, while pallet straps are designed for single-use stabilisation and cannot reliably maintain performance after removal. In industrial logistics environments—where high loads, repeated handling, and long transport distances are standard—any reduction in load-securing performance can pose risks to workers, compromise product integrity, and affect transport safety.

The organisations therefore warn that maintaining the 40% reuse target for these formats risks creating a regulatory framework that is difficult to implement consistently and raises concerns regarding legal certainty and proportionality. A fragmented approach could also undermine broader EU objectives related to simplification, competitiveness, and industrial resilience.

Against this backdrop, EDANA and more than 70 co-signatories call on the European Commission to adopt a delegated act extending the exemption to the 40% reuse target under Article 29(1), and to include comparable transport packaging solutions. Prioritising recyclability or recycled content in cases where reuse is technically unsuitable is, according to the statement, essential to ensure that the regulation remains workable and fit for purpose.

The full joint industry statement provides a detailed assessment of the technical, operational, and policy implications of reuse targets for transport packaging.

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