On the 15th of October 2025, PubAffairs Bruxelles organised an afternoon of discussion on whether the EU institutions will adopt a pragmatic approach to the reuse targets for transport packaging. The event was also be a timely opportunity to discuss the current state of play of the EU Packaging and Packaging Waste Regulation (PPWR), with a focus on the implementing and delegated acts under development, with our distinguished speakers: Christian Zörner, Head of Office and Advisor to Andreas Glück MEP, Renato Zelcher, CEO, CROCCO, Ángel David Hernández, President, European SafeLogistics Association (EUMOS), Benedikt Kauertz, Scientific Director and Head of Department Industry and Products, Institute for Energy and Environmental Research (IFEU) and Tristan Salmon, Senior Economist, RDC Environment gave a keynote speech and participated in the panel. Thomas De Meester, Head of EuPF gave the introductory remarks.
The debate was moderated by Eleonora Rinaldi, Energy and Climate Correspondent, MLex.
Eleonora Rinaldi opened the event by welcoming the audience and summarising the topics of the debate by informing that the discussion would have been preceded by two keynote speeches in order to provide the attendees with a detailed overview of the economic and environmental data that the European Commission shall take into account when assessing the impact of the proposed regulation on packaging and packaging waste. She then invited Thomas De Meester to deliver the introductory remarks.
Thomas De Meester welcomed the participants to the first official event of European Plastics Films (EuPF), expressing appreciation for their attendance and highlighting the timeliness of the topics under discussion. He explained that the debate would focus on the re-use targets for transport packaging set out in Article 29 of the EU Packaging and Packaging Waste Regulation (PPWR). He provided an update on the current state of play, emphasising that the day of the event was of particular significance due to the meeting of the European Commission’s Waste Expert Group, during which the delegated act providing an exemption for pallet wrapping and straps was under discussion.
He then introduced EuPF, a sector group of EuPC (European Plastics Converters), which serves as the voice of the European plastics converting industry. Mr De Meester explained that EuPC brings together 28 national associations and 18 sectoral organisations, including EuPF, and represents a total of 50,000 companies placing around 50 million tonnes of products on the market. He further outlined that the plastics converting industry as a whole generates a turnover of €260 billion and employs roughly 1.6 million people across Europe. He also stated that EuPF was established by five founding members and has already expanded to thirteen members. He then noted that the question of the re-use targets introduced by the PPWR is among the key issues uniting the association.
The speaker subsequently provided an overview of the main characteristics of pallet wrapping, which, he said, exists in three adaptable formats designed to meet diverse needs. He underlined the advantages of single-use plastic wrapping, describing it as lightweight, circular, fully recyclable, and frequently composed of recycled material. He further noted that these wrappings ensure safety and efficiency by stabilising loads, protecting goods, and facilitating logistics through automated pallet-wrapping systems. At present, he observed, no alternative offers comparable functionality, and replacing current solutions would risk higher export costs and disruptions to supply chains. He therefore stressed that altering palletising methods would effectively entail a transformation of the entire European logistics system.
Mr De Meester then outlined that Article 29 of the PPWR consists of three parts: Paragraphs 2 and 3, establishing a 100% re-use obligation by 2030 for packaging used by economic operators within the same EU member state or between linked enterprises, and Paragraph 1, which introduces additional re-use targets of 40% by 2030 and 70% by 2040 for packaging traded within the European Union’s borders. Among the specific packaging formats explicitly covered, pallet wrapping and straps are included, he specified.
He subsequently mentioned that the Regulation foresees the possibility of exemptions under Article 29(18) on environmental or economic grounds, and stated that the following panellists would elaborate on the reasons why EuPF considers that the criteria for exemption are fully met in the case of plastic pallet wrapping.
The speaker then provided an update on the EU’s current state of play regarding the file, referring to the above-mentioned Expert Group meeting. In this regard, he noted that the European Commission announced the forthcoming publication of a delegated act exempting pallet wrapping and straps from the 100% re-use target under Article 29. However, he also highlighted that no exemption was foreseen for the 40% re-use target set out in Article 29(1), as the European Commission had argued that existing market alternatives were sufficient to achieve the 40% target and, therefore, did not justify further derogations. He also added that the EU executive body was preparing an implementing act under Article 30 to define a methodology for calculating re-use targets, including pallet stabilisation elements, and was reportedly seeking a “practical and realistic approach.” Nevertheless, he cautioned that if the forthcoming methodology reflects what the Commission has previously presented, it cannot be considered as an adequate substitute for a derogation under Article 29(1).
Addressing what he described as a common misconception, Mr De Meester explained that re-use targets would not be calculated on the basis of weight, but rather on the number of equivalent units, as specified in Article 30(1) of the text adopted during the trilogue negotiations. He referred to an example previously presented by the European Commission during a December 2024 webinar, in which a transport unit comprising a pallet, shrink film wrapping, and 24 cardboard boxes yielded a total re-use rate of 50%. However, he pointed out that, as pallet wrapping and straps are often used together, this calculation method could result in significantly lower re-use rates, such as 33%, and even combining the two components as a single equivalent unit would not make it possible to reach the aspirational 70% target by 2040. He further noted that the assumption that pallets themselves are reusable is not always true in practice. Consequently, EuPF believed that the proposed calculation method would not deliver the intended regulatory relief.
He then argued that maintaining the exemption under Article 29(1) remains essential for three principal reasons. First, environmental issues, as they are grounds for exemption under Article 29(18c), given that reusable options lead to higher CO₂ emissions compared to optimised single-use solutions, with the environmental impact increasing with transport distance. Second, economic constraints, particularly the risk of reduced EU competitiveness due to higher costs across key sectors and the need for exporters to operate dual systems for EU and non-EU markets, thereby undermining the efficiency of the internal market. Third, technological readiness, as standardised reusable pallet wrapping systems will not be available at scale before 2030. He added that these conclusions were reaffirmed that same day during the Waste Expert Group meeting, where Deloitte—commissioned by the European Commission to assess the feasibility of the reuse targets for pallet wrapping and straps—presented findings aligned with this assessment.
The speaker concluded by giving the floor to his colleagues, who would provide further insights into the key findings of two recent studies assessing the environmental and economic implications of transitioning the transport packaging sector from single-use to reusable systems.
The moderator, Eleonora Rinaldi, subsequently took the floor and noted that the debate would turn to the environmental dimension of the issue and invited Benedikt Kauertz, Scientific Director and Head of the Department of Industry and Products at the Institute for Energy and Environmental Research (IFEU) to present his assessment.
Benedikt Kauertz presented the findings of a life-cycle assessment (LCA) carried out on transport packaging systems. He explained that the study examined both single-use and re-use transport packaging systems. He specified that the single-use options considered included plastic and paper-based systems, while the re-use systems comprised both flexible and rigid solutions – the latter mainly produced from plastic, with one variant made of cardboard.
He also emphasised that an important point to bear in mind is the difference in weight among the various systems. For example, a single-use transport packaging system made from plastic contains a 21.5 kg wooden pallet, which is, in most cases, a reusable system and an additional 140 g to 1.5 kg of plastic film, depending on whether stretch wrap or shrink/stretch hood applications are used. These, he noted, vary according to the field of application. In contrast, rigid reusable systems made from plastic weigh approximately 48–50 kg, with variations in height also observed.
Given these differences, the study did not compare packaging systems on a one-to-one basis, but rather through a defined functional unit. The chosen functional unit, he said, was the delivery of 1,000 kg of packed goods, including both sales and group packaging, transported to their destination. Accordingly, the analysis calculated the number of packaging units required to fulfil this function, he added.
Referring to a table displayed on screen, Benedikt Kauertz noted that the study covered a range of applications, including cardboard boxes, water bottles, milk bottles, polymer bags, cement bags, buckets and new glass bottles transported from manufacturers to fillers. The data indicated that the number of packaging units needed to meet the functional unit varied significantly depending on the application. In most cases, however, single-use transport packaging required fewer units to deliver the same quantity of goods, owing to the possibility of higher stacking and better load efficiency, he said. He also added that this efficiency factor was often overlooked in discussions of re-use systems, which, he cautioned, are not always optimally adapted to the specific products being transported and, as a result, could lead to load inefficiency, as illustrated by the example of glass bottles.
Turning to the climate-related results, Mr Kauertz presented the findings concerning greenhouse gas emissions across the various application fields. He pointed out that, in all the cases analysed, the climate impact associated with re-use systems was higher than the one observed for single-use systems. The results were then integrated into a comparative chart displaying the range of values obtained for each system.
The lower bound represented the minimum emissions (for instance, those associated with cement bags in single-use systems), while the upper bound reflected the maximum emissions (such as those for glass bottles), he pointed out. Against this backdrop, he highlighted two main observations. First, that there is a considerably wider range of results for re-use transport packaging systems compared to single-use systems, indicating greater variability and uncertainty. Second, he noted that single-use transport packaging consistently exhibited a lower environmental and climate footprint than the re-use alternatives.
Benedikt Kauertz then proceeded to examine the main factors driving these outcomes, remarking that distribution emerged as the dominant contributor to environmental impact. In most cases, he explained, distribution accounts for more than 50% of the total environmental burden of re-use transport packaging and, in certain cases, for more than two-thirds of total carbon emissions. While distribution could also be relevant for single-use systems, its impact is not always predominant. He then stated that the degree of influence depended on the weight-to-volume ratio of the packed product: namely, transport emissions were more significant for goods with low weight and high volume, whereas it is the opposite for heavy, compact products. Nonetheless, distribution was in most cases the relevant factor for re-use packaging systems, he stated.
Benedikt Kauertz concluded his speech by underlining that the life-cycle assessment conducted by IFEU was fully compliant with ISO standards and had undergone independent third-party review, covering all aspects of the Product Environmental Footprint (PEF) methodology. He observed that, had the proposed Green Claims Directive been in force, the study would have met its requirements, as it was designed to be fully compliant to that piece of legislation.
Summarising the core findings of the study, Benedikt Kauertz stated that, in most application fields, single-use plastic transport packaging outperformed rigid re-use systems and, in many cases, also delivered better results than flexible re-use systems. The key determinant of these findings, he reiterated, was distribution. Single-use systems enable higher truck utilisation due to their superior size adaptability to the goods being transported. He also stressed that the overall quantity of packaging required for single-use systems was considerably lower, which further contributed to their environmental efficiency.
Eleonora Rinaldi announced the second keynote speaker, namely Tristan Salmon, to present some economic findings stemming from a study he participated in.
Tristan Salmon firstly pointed out that his team had conducted a parallel, independent economic study. He provided a brief introduction of his organisation, noting that RDC Environment is based in Brussels and has offices in France, and employs economists and engineers working on life-cycle assessments, circular economy projects, cross-benefit analyses and activities linked to EuPC conferences.
He explained that the study assessed the transition envisaged under Article 29, namely moving from a single-use plastic covering to a reusable solution, such as a reusable hood. He observed that numerous configurations existed depending on the product, including boxes and sleeves, and emphasised that the same flexibility applied to plastic, which needed to be adapted according to stability requirements.
The objective of the study, he said, was to quantify the economic implications of such a transition. To achieve this, his team analysed eight representative products across eight sectors, evaluating the impact on production costs, including factory operations, palletisation, machinery, labour and logistics. The study aimed to provide both a long-term perspective, envisioning potential future automated reusable solutions, and a short to medium-term assessment of transition costs, such as investment in new machinery and logistics adaptations.
Tristan Salmon presented the results, noting that the estimated annual increase in production costs varied considerably between products, from €79 million per year for insulation rolls to slightly over €3 billion for glass bottles. He explained that these differences were attributable to both the volume of products sold within the EU and the relative difficulty of replacing certain goods with reusable alternatives, citing glass bottles as particularly challenging compared with more flexible and adaptable products.
He further outlined the projected investment required for machinery to implement reusable solutions, estimating approximately €8 billion over a 15-year lifecycle. This estimation, he clarified, focused only on machinery replacement and installation, and did not account for potential changes in factory logistics or the rearrangement of production lines.
Tristan Salmon also highlighted several short to medium-term challenges identified in the study. For example, he noted that automated machinery capable of efficiently handling reusable hoods, boxes or other packaging components did not currently exist and would require significant development. Additionally, many production lines would need to be modified, particularly in cases where pallets were partially single-use and partially reusable, which could necessitate duplication of, among other things, lines, increasing costs, demand and space.
Finally, he addressed the potential for competition between solutions during the medium-term transition period, as different systems were tested and optimised for various sectors. He also warned that multiple competing standards could complicate reverse logistics, including the collection, preparation and return of packaging, thereby further complicating the whole process.
Eleonora Rinaldi thanked the keynote speakers and presented the panellists by anticipating that that she would have liked to start the conversation with the environmental and economic findings that had been presented. Consequently, she asked whether the panellists were surprised or worried by the findings presented starting from Christian Zörner, Renato Zelcher and Ángel David Hernández.
Christian Zörner explained that he was surprised by how clear the results were in both economic and environmental terms, as well as by the fact that re-use was not always better than single use. He recalled that there had been an intense debate at the time when the PPWR was negotiated. He welcomed the fact that scientific evidence has highlighted these criticalities and stated that they clearly needed to be addressed.
Renato Zelcher said that he was not surprised at all, having been in the business for several years. He then explained that this was exactly the reason behind the commissioning of these studies, namely, to bring scientific evidence into the policy debate. He illustrated his point with an example regarding plastic stretch wrap, noting that, with 25 kg of film, one could wrap a load of 25 tonnes of pallet.
He also emphasised that this particular use of plastic wrap has been developed over time because it has been the best solution available. He added that, in business-to-business interactions, the film is collected and, most of the times, recycled and reused in other applications. He then stated that the evidence emerging from the two studies apply to Articles 29(2) and 29(3) and Article 29(1). He subsequently argued that a robust stakeholder alliance was needed as rules could not simply be imposed in a top-down fashion. For these reasons, he stressed the importance of technology neutrality. He concluded that ambitious targets can be accepted on the condition of knowing how to achieve them. Otherwise, the competitiveness of the European economy would be undermined.
Ángel David Hernández agreed with Renato Zelcher, noting that his own experience had led him to similar conclusions, which were also reflected in analyses conducted by EuPF, EuPC, IFEU, Hoffer, and GVM. He said the results were not surprising, but did raise certain safety-related concerns. He then explained that logistics chains – from the packer, through transport and distribution, to the retailer – are central to his association’s work.
The speaker highlighted two main issues. First, material properties could be compromised, particularly when incorporating a certain percentage of post-consumer recycled (PCR), which may affect strapping, welding, or stretch film and potentially require thicker films, thereby counteracting environmental objectives. Second, he warned that workers’ health could be at risk. Indeed, despite high levels of automation and fast-running machinery, reintroducing reusable systems would require workers to operate around the same machines and platforms.
He concluded that these two matters, namely material performance and worker safety, are especially significant in a highly automated European context.
Christian Zörner said that it was positive to finally have the data, and noted that it would have been preferable to have the abovementioned findings before the legislation was adopted. Reflecting on the process, he referred to the very late trilogue agreement that had unexpectedly added the three paragraphs. He remarked the time spent on this file, suggesting that perhaps there was a need to rethink how policy are sometimes put in place.
The moderator thanked him for that comment and stated that she wanted to explore the process a little further. She observed that, as she understood it, the original targets proposed by the European Commission have not been the same as those finally adopted, and asked Mr Zörner whether that was correct.
Christian Zörner confirmed, explaining that the re-use targets did not apply only to transport packaging, but also included rules for beverages, both alcoholic and non-alcoholic, within a single extensive article. He emphasised that the inclusion of 100% re-use quotas for sales packaging used for transport had been particularly significant, as well as the distinction between sales packaging and transport packaging, which had initially been upheld and which he believed remained important.
He gave the example of a paint bucket, where the packaging becomes contaminated by the product itself, contrasting it with straps or wrappings. He explained that this issue had formed part of a very late agreement reached during the trilogue negotiations. Once that agreement had been made, it became extremely difficult to reopen the discussion, as altering one element risked unravelling the entire package.
He noted that Andreas Glück MEP tabled some late amendments, which caused a degree of panic, and, as a result, the European Commission promised to exempt pallet wrapping and straps. He also said it was positive that some critical aspects had emerged from the process, but acknowledged that not all the criticalities have been resolved yet.
Eleonora Rinaldi asked whether there was still room to act at the European Parliament level now that the delegated act has been announced.
Christian Zörner replied that the Parliament only had two options: either to approve or to reject the delegated act, with no possibility of a partial agreement. He also said it remained to be seen how the process would develop, but he was sure the issue was not yet settled.
Eleonora Rinaldi then asked whether he believed it was likely that the delegated act would be rejected.
Christian Zörner responded that this would be a fairly high hurdle, as an absolute majority was required both in committee and in plenary and added that, with sufficient mobilisation, it could be possible – particularly given the new parliamentary majorities – but he cautioned that such a step should be approached with moderation.
The moderator observed that much of the discussion has been centred on Article 29, and said she wished to understand the reasons why this particular provision had attracted such strong attention. She also noted that extensions were granted for Articles 29(2) and 29(3), but not for Article 29(1), and asked what made this situation problematic. The question was directed mainly to Mr Renato Zelcher and Mr Ángel David Hernández.
Renato Zelcher replied that the answer was straightforward, as the studies already made the situation clear. He said that, while the industry was naturally defending its position as producers of plastic film, the problem extended far beyond their own sector. The main issue, he explained, lay with their customers, who need to package their goods. The current uncertainty, he continued, is blocking investment as companies do not know in which direction to move. Uncertainty, he remarked, is the worst enemy of the economy, as it discourages investment and makes it extremely difficult to develop future business plans. As a result, companies tended to wait and see how matters would evolve.
Referring to the data already presented, he said that the findings indicate higher costs, no improvement in environmental impact and a negative effect on competitiveness. He stressed that it would be impossible to operate two parallel systems – one for intra-EU trade and another for exports – as this would lead to confusion and inefficiency. He concluded that Europe continues to reflect on competitiveness, while, in his opinion, further action is needed.
Ángel David Hernández agreed, noting that reusable packaging was not a new concept, as the European industry has been using it for many years according to its own strategies, either through internal systems or through pool arrangements. He also underlined, however, that the major challenge does not lie in rigid packaging, but in flexible packaging, which could not be reused. He stated that the key responsibility of all stakeholders, industry, consultants, packers, brand owners etc. is to ensure that waste was properly collected, which, he noted, is still not the case. Indeed, in his opinion, the main challenge remains in the area of flexible packaging, while rigid packaging already benefited from effective solutions, such as reusable crates for fruit.
He further explained that all decision-making and the accompanying life-cycle analyses should be based on real LCA data. The industry, he said, has a deep understanding of efficiency and knows which solutions works best in terms of weight and performance. As an example, he referred to the inefficiencies that would arise if an additional 40 kilograms were added per load unit, multiplied by 32 pallets, significantly affecting transport performance. These, he said, were issues that the industry is capable of solving. What had been overlooked, he stressed, was the recovery of waste, particularly flexible waste, which needed to be properly collected at the end of the supply chain, notably at retailers’ platforms and distribution centres. He suggested that this should form the basis of a plan for the sector to put forward as a way out of the current impasse.
Renato Zelcher added that the industry has been discussing recycling for many years and had therefore moved rapidly towards recyclability. He acknowledged that progress has not been sufficient, as much attention continued to be given to what has not yet been achieved; nonetheless, he emphasised that significant advances have been made. Citing Italy as an example, he explained that the country had started from zero and, by 2024, it had recycled 55% of plastic packaging, already in line with the reuse targets proposed at EU level. He conceded that more remained to be done, yet underlined that concrete progress has been achieved. He also noted that, while other data from some EU member states might differ, Italy’s figures are certified by Eurostat.
He concluded by saying that the industry has embarked firmly in this direction when, suddenly, the narrative shifted from “recycling is good” to “reuse is better”. He also argued that the rules could not be changed continuously, reminding the audience that the sector employs 1.6 million workers across Europe. As a result, he called for a clear, forward-looking and long-term approach for the benefit of the European economy as a whole.
Eleonora Rinaldi asked whether Europe’s packaging industry is currently well equipped to compete with foreign suppliers.
Renato Zelcher stated that Europe continues to be fit for competition, provided that the rules of the game are not changed. If rules are changed, he warned, the sector would risk losing its competitiveness. He also stressed that the industry possesses the necessary technology, know-how and willingness to invest; at the same time, it needed clarity in order to move forward.
Ángel David Hernández said that he fully agreed with Mr Zelcher. He explained that, in terms of technology, Europe is indeed well prepared, but significant external threats exist, particularly regarding feedstock. He added that, if new regulations are to penalise the local industry, the situation would deteriorate further. He observed that the current legislative proposals are creating confusion across the sector, as Mr Zelcher also highlighted.
Mr Hernández also noted that the largest plastics industry event was currently taking place in Düsseldorf, and highlighted that several actors signalled that they are struggling to adapt to an uncertain future. He also argued that concluding the current regulatory process and providing clarity to decision-makers would be beneficial for European businesses as a whole. Echoing Renato Zelcher’s remarks, he concluded by saying that although the industry was ready to increase its commitment, several major investments have been put on hold, creating opportunities for competitors from other regions to overtake European producers.
The moderator then read a question submitted via Sli.do, asking how the European Union intended to ensure that non-EU manufacturers complied with the PPWR requirements and what tools were planned to verify such compliance.
Renato Zelcher replied that the industry itself is also asking how such compliance could be guaranteed. He pointed out that even under the existing framework on recycled content, substantial difficulties already existed. Referring to Spain, he noted that a plastics tax is applied there, with exemptions based on the percentage of post-consumer recycled (PCR) content in the product. However, he stated that Europe is currently experiencing some flow of imports from outside the EU accompanied by full certification of recycled content, despite the origin of that content being unknown.
Christian Zörner added that, in his view, the question is primarily one for the European Commission. He explained that all packaging placed on the EU market, regardless of whether it originated within or outside the Union, must comply with the same criteria. He also noted that the issue is also linked to the 100% re-use quotas that applies within a company or within the same country. Quotas which, he argued, discriminates against small and medium-sized enterprises that mainly serve local or national markets. Larger companies, he stated, often operate across borders or export outside the EU, whereas smaller firms are disproportionately affected by the new rules. He then observed that this situation increased operational costs, particularly for products such as strapping and wrapping, but also for a broader range of packaging formats. Mr Zörner concluded that a proper life-cycle assessment should be conducted for all packaging formats mentioned in the legislation, and that the European Commission should act on the evidence produced.
Ángel David Hernández addressed the original question by highlighting the difficulty of establishing reliable metrics to verify compliance. He warned that this complexity risks fostering a black market, as some certificates are being issued by entities located far away with limited traceability. He argued that it was nearly impossible to determine whether a product contained, for example, 35% or 50% recycled content.
The more complicated the metrics becomes, he cautioned, the easier it is for illicit practices to emerge. Referring again to the Spanish case, he explained that the system depends on accurate measurement of PCR content to determine whether a special tax applied. Yet he questioned who ultimately bears responsibility for verifying this information, namely the importer or the producer, especially when the producer might be located 10,000 kilometres away in a country without mechanisms to enforce liability. He concluded that, as long as the metric remains difficult to implement, illicit practices would inevitably arise.
Renato Zelcher added that he had recently attended a meeting where one figure had particularly struck him: Europe currently receives around 6.9 billion e-commerce packages from Asia and, as these shipments fell below the €150 threshold, they are not subject to any form of control.
Eleonora Rinaldi asked whether, considering all that had been discussed, there was truly a trade-off between adopting reused materials on one hand and reducing costs and emissions on the other, or whether a “third way” might exist.
Tristan Salmon responded that, from an economist’s perspective, the answer depended largely on the specific product category. He explained that identifying a “third way” goes beyond the scope of the study he and his team had conducted. However, he cautioned against overgeneralising, noting that, while re-use systems might make sense for certain products, for others they could be considerably more challenging to implement effectively.
Benedikt Kauertz stated that, from a life-cycle assessment perspective, the findings are quite clear. He explained that, in most cases, the results were primarily driven by the quantity of packaging material required. In his view, there was no point at which a break-even could realistically be achieved between a highly optimised single-use transport packaging system and a rigid, heavy re-use transport packaging system.
To illustrate his statement, he noted that, if a re-usable box weighed around 50 kilograms, even assuming a trip rate of 100, this would still require roughly 500 grams of new material to fulfil the same transport function. By comparison, a single-use transport packaging solution might require only 150 to 160 grams of material.
For this reason, he argued, a break-even point would never be reached and, in any case, a trip rate of 100 was largely unrealistic. He further explained that transport packaging was not only used for transport but also for storage and docking in warehouses, and that there were no clear data available on the actual number of rotations per year that a reusable transport packaging unit could achieve.
Benedikt Kauertz concluded that, when the re-use targets for transport packaging had been set, there had perhaps not been sufficient scientific knowledge or understanding of these dynamics. He added that this lack of consideration was clearly visible in the environmental assessment of the PPWR, where the issues had been raised but not adequately addressed.
Ángel David Hernández proposed a shift in focus, suggesting that the common objective should be framed differently. He stated that, for example, by 2030 the aim could be to reduce packaging by 30% per kilogram transported, representing a preventive approach that would allow the industry to do more with less. He emphasised that the industry already possesses solutions to achieve such targets and noted that all actors – from resin producers and petrochemical companies to distributors and converters – are fully prepared to meet this objective. He added that it was crucial to start by helping regulators understand what could realistically be achieved, with prevention as the primary goal. Once that was agreed, he suggested, the remaining 70% of packaging could then be addressed with additional solutions.
Renato Zelcher stated that he fully agreed and added that a “third way” is always possible, with innovation playing a central role. He illustrated this using stretch film as an example, noting that production in the early 1980s involved films 35 to 40 microns thick, whereas today films are produced at 5 microns. He explained that, although the total amount of packaging appears to have increased, packaging per unit has actually decreased, with overall volumes rising due to increased goods transport. He also observed that public discussion tends to focus solely on packaging itself, ignoring the broader context, and concluded that there remained room for innovation. He also noted that, while the main aim of the PPWR is to reduce waste, simply switching from plastic to alternative materials did not necessarily achieve this objective, and that opportunities still exist to improve packaging performance.
Ángel David Hernández asked Renato Zelcher what percentage reduction could realistically be achieved in the near term.
Renato Zelcher replied that this would depend on the specific application. He suggested that, for some products, a 30% reduction could be achieved without difficulty, whereas for others, the industry is already approaching technical limits.
The moderator asked the panellists, with the regulation now adopted and with upcoming delegated and implementing acts expected, what could still be done through the secondary acts.
Christian Zörner replied that one possibility is to exempt certain measures that have been included for the wrong reasons. He noted that the scope for delegated acts is limited, as the entire Regulation could not be changed and, as a result, the European Commission’s powers are constrained. He added that the broader competitiveness agenda included omnibus initiatives, including one on environment-related questions. He also explained that he could not predict what might ultimately be included, but suggested that the PPWR could potentially be part of such initiatives.
He also emphasised that, although the regulation is extensive and complex and allows room for improvement, stakeholders are not in a particularly powerful position at this stage of the process. He explained that the legislation has already been adopted by the co-legislators, and that all that could be done at present is to adopt or reject the delegated acts. The initiative, he stressed, remained with the European Commission.
He also added that parliamentary questions had been submitted to the European Commission, and letters written on the issue – including one co-signed by 25 MEPs – that, he noted, was remarkable for such a niche topic and demonstrated the sensitivity of the matter.
Renato Zelcher asked whether there is a clear timeline for these actions.
Christian Zörner replied that the environmental omnibus is planned for the fourth quarter, but that the call for inputs is now closed and has received a large number of contributions. As a result, he suggested that the process could be delayed until the following year.
Eleonora Rinaldi asked whether, at this stage, the European Commission has been receptive to the letters and questions submitted, and whether the same applied to the industry.
Christian Zörner replied that the letter sent to the European Commission, co-signed by 25 MEPs, has not received a response, nor has another previously submitted letter. He suggested that this might reflect a political decision of non-engagement, noting that letters on other topics received a reply. He concluded his reply by stating that it is important for both industry and scientific evidence to support such initiatives.
Renato Zelcher emphasised the need for more dialogue. He clarified that the intention is certainly not to act in bad faith or to impose new regulation, but rather to engage in informed discussion because the industry possesses the relevant expertise. He acknowledged that some progress has been made but stressed that the industry needs to be better heard.
Ángel David Hernández underlined that, as representatives of safety, his organisation’s position was always based on science. He stressed that clear participation from all stakeholders was essential in order to redefine objectives, rather than merely deciding whether to implement them. He further explained that, beyond science-based studies, there are critical safety concerns. He cautioned that it was not feasible to revert to technical specifications from 25 years ago or to tolerate large standard deviations in packaging performance. He also warned that moving from narrow tolerances of 2–4% to much wider deviations of 12–20% would significantly compromise safety, particularly in the calculation of packaging and cargo securing, which would be strongly and seriously affected by such changes.
The Q&A session also covered the following issues: the challenges in achieving the 40% packaging re-use target by 2030 and the gap between policy ambitions and industrial readiness; the limitations of current reusable packaging options under Article 6 requirements for recyclability; the economic implications of reuse targets, including the estimated €5 billion annual burden across selected sectors; the cope and the definition of the issues within Article 29, particularly regarding different types of packaging like cold chain transport boxes; the uncertainty around enforcement and sanctions for packaging lacking verifiable post-consumer recycled content; the role of recycled content versus reusable packaging in reducing greenhouse gas emissions and promoting a circular economy; the importance of fact-based policymaking and science-driven recommendations for the European Commission.
Do you wish to know more about the issues discussed in this debate? Then check out the selected sources provided below!
EU Packaging and Packaging Waste Regulation, European Commission
New EU rules to reduce, reuse and recycle packaging, European Parliament
Comparative life cycle assessment of various single-use and reuse transport packaging, IFEU
Economic impact of switching to reusable options for pallet wrapping, RDC Environment
Consequences if replacing single-use plastic pallet wrapping with reusable alternatives, EuPF
How to stay competitive under the Packaging and Packaging Waste Regulation, EY
Towards 2030: Will the EU meet its packaging waste reduction targets?, Innovation Network
Navigating the EU Packaging and Packaging Waste Regulation, Deloitte
