The European Safe Logistics Association – 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 two specifically mentioned cargo securing systems have been extensively tested and they have been able to considerably reduce transport accidents.
EUMOS considers it its duty to emphasize that the PPWR builds on an assessment framework for the implementation of the provisions on reusable packaging for the transport of goods on pallets that is primarily focused on ecological and economic factors. However, the aspect of load unit security and transport safety is not adequately taken into account in the legislative text. The criteria for exemptions from the targeted obligations are listed in Article 29(18)(a) (“particular economic constraints”) and article 29(18)(c) (“environmental issues”), which do not explicitly address transport safety. EUMOS considers it imperative that not only the ecological and economic impacts but also the implications for load unit stability and transport safety must be properly taken into account when drafting the delegated act.
In the study conducted by Deloitte on behalf of EU DG ENV, it is clearly demonstrated that flexible plastic wrappings and straps provide the highest level of load unit stability (see Section 4.2.1). Furthermore, tests conducted in accordance with the Standard EUMOS 40509 on reusable transport packaging — particularly the tests on the life cycle assessment by the Institute for Energy and Environmental Research Heidelberg (IFEU) entitled “Comparative life cycle assessment of various single use and reuse transport packaging,” (reference no. [70] in the Deloitte study) — reveal significant weaknesses in transport safety for the commonly used reusable load securing systems, as represented by the A-profiles in the Deloitte report, when compared to stretch films and straps.
In particular, manually applied reusable sleeves (Figure 10 (1), page 22 of the Deloitte study) show considerable deficiencies and do not comply with the Standard EUMOS 40509 nor are they recyclable. It should also be noted that automated packaging processes — which represent the current state of the art for stretch films, stretch hoods, shrink hoods and straps — ensure standardized and reliable load unit security. This level of consistency cannot be achieved with manually applied reusable systems, which lack proper interlocking, have insufficient fitting, and do not provide a secure connection to the pallet base. The Fraunhofer scientific study ”Analysis of the damage behaviour of strapping tapes under different load cases”, conducted on initiative of Project Alliance Strapping, further confirms significant increased logistic safety risks throughout the value chain in case of mandatory reuse of pallet straps over recycling.
While EUMOS expressly welcomes the announced exemption for single-use pallet wrappings and straps from the 100% reuse targets according to Article 29(2) and (3) of the PPWR, 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.
In our view, the currently available alternatives to stretch films and straps do not enable the achievement of the 40% nor 70% reuse target in a technically feasible or safety compliant manner. Moreover, Article 29(1) would impose a significant administrative burden on all European actors in the value chain, as every pallet in Europe would need to be individually assessed and documented, which would have considerable impacts on the entire European logistics, whereas rules and measures for transport packaging on imported packed goods are non-existing.
In summary, EUMOS supports the EU Green Deal and the Circular Economy Action Plan for a cleaner and more competitive Europe and – within this framework – the need for revision of the rules for packaging and packaging waste previously in place. EUMOS is also 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 – has stated 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.
Background to EUMOS: The European Safe Logistics Association – EUMOS – is a non-profit association devoted to improving safety in the logistics chain. EUMOS relies on the exchange of best practices when working on safety standards for logistics in all transport modes. Thanks to the width of expertise by its members, EUMOS manages to ensure that all elements of safety are considered when speaking with one voice in the interest of logistics safety. EUMOS’ members are private and public bodies involved in logistics safety, load stability and cargo securing.
Links to studies conducted by industry:
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