Eumos strongly welcomes the planned exemptions for pallet wrap and strapping from the 100% reuse obligations for transport packaging in the new Packaging and Packaging Waste Regulation (PPWR) as recently announced by the European Commission. This announcement follows the publication on 6 October 2025 of a study carried out by Deloitte entitled “Study on the exclusion of plastic pallet wrappings and straps from the 100% reuse obligations of transport packaging in the PPWR”. We are grateful for the upcoming exemptions and the Commission´s commitment to ensure the efficient handling of safe packaging and cargo securing systems in Europe. These cargo securing systems have been extensively tested and they have been able to considerably reduce transport accidents.
However, we strongly urge the inclusion of an assessment of the impact of reusable load carriers as referred to in Article 29(1) in the evaluation process, to ensure that their effects on transport safety are duly considered. The currently available alternatives to stretch films and straps do not enable the achievement of the 40% reuse target in a technically feasible or safety compliant manner. The provisions would impose a significant administrative burden on all actors in the value chain, as every pallet in Europe would need to be individually assessed and documented. Tests conducted in accordance with the Standard EUMOS 40509 on reusable transport packaging reveal significant weaknesses in transport safety for the commonly used reusable load securing systems.
Eumos is fully committed to the logistics safety efforts in Europe and is devoted to contribute actively to the ongoing revision of the EU Directive on the Roadworthiness Control of Commercial Vehicles. Angel Hernandez – Chairman of EUMOS – recently stated in an event hosted by the European Plastic Films industry that “Europe is home to the safest roads in Europe and we should pride ourselves in keeping this status”. Circular Economy and Safety should therefore together provide the framework for transport packaging rules.
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