EUMOS is highly concerned about the draft text of the EU Packaging & Packaging Waste Regulation as provisionally agreed by the EU Institutions on 4 March 2024 as it compromises Transport Safety.

The targets proposed for the re-use of material for transport packaging are not practically feasible based on two reasons:

1. Re-use of the materials mostly used in transport packaging (stretch film, stretch hood, shrink film, strapping) is not possible as they cannot return to their initial morphology. Insisting on the re-use of the left-overs of these types of packaging would create inefficiencies and cause safety hazards.
2. Safe Cargo is conditioned by the combination of the quality of Primary, Secondary and Tertiary Packaging. The Integrity of a Load Unit is seriously affected by the 3 involved types of packaging. Any consideration must consider the Safety of a Load Unit as a whole.

EUMOS has requested EU legislators to review these considerations and to find procedural ways of working on solutions for handling these questions in the interest of a workable legislation.