The undersigned associations and companies, representing the reusable transport packaging value chain, urge the European Parliament to maintain the reuse targets for transport packaging used for transporting products i) between sites of the same economic operator or linked/partner enterprise, and ii) within the same Member State, as previewed in article 26.2 and 3 of the Packaging and Packaging Waste Regulation (PPWR).
Recently, various trade associations addressed letters to policymakers requesting the elimination of the reuse targets in the above mentioned use cases. Legislation cannot be shaped by the inaccurate argumentation put forward by those who claim that reusable alternatives to pallet wrappings and straps are not technically possible. These statements contain no evidence and are actually incorrect. There is a wide myriad of reusable transport packaging solutions, including for pallet wraps and straps, as you can see in the Annex below. Change requires innovation and it is entirely feasible to move over to reusable pallet wrappings and straps, as these solutions already exist and are easily scalable. Moreover, reusable transport packaging such as crates, trays and pallets, can be designed to be fully stackable without single-use wrappings and straps.
Transport packaging serves an important role in transporting raw materials and products in-between the many stages of modern global supply chains. They act as a barrier to external elements, allow for safe handling of bulk quantities and provide load stability to their content. For this reason, standards are strict and testing extensive. For example, flexible intermediate bulk containers (FIBCs) have a dedicated ISO-standard (ISO 21898) that specifies the strength and minimum test requirements for such packaging. These norms have already existed for many years, demonstrating its feasibility in practice.
Interestingly, the single use packaging industry’s claims focus solely on eliminating this specific type of packaging, while they advocate for removing the targets across all forms of transport packaging. In addition, it is mentioned that transport packaging will have to be 100% reusable from the entry into force of the PPWR, ignoring deliberately the numerous exemptions established within this category: i) transportation of dangerous goods, large scale machinery, equipment and commodities with custom-designed packaging, ii) flexible packaging in contact with food, and iii) cardboard boxes). This approach is misleading and unacceptable.
Removing paragraphs 2 and 3 from article 26 would also mean removing the low-hanging fruit for Member States to prevent waste, as reuse in the transport packaging sector has already been a trusted option for businesses for over 60 years.
Over the last years, companies have been investing hundreds of millions of euros in developing cost-efficient and environmentally sound reuse systems for transport packaging in Europe. The sector is constantly innovating to provide solutions that remove the necessity for single-use. These investments have led, inter alia, to outperform single-use alternatives in many aspects (Fraunhofer, 2022). In the case of reusable plastic crates, they excel over single-use carton boxes in 15 out of 17 categories, including lower breakage rate, lower greenhouse gas emissions throughout a lifecycle, where optimized transport, number of rotations all play a role, and better material efficiency and recycling rates. In particular, reusable pallet wraps account for up to 90% reduction of greenhouse gas emissions and 95% of waste reduction over 150 uses. Besides, recent innovation has led to improving the reusability of cardboard boxes, boasting its use to at least 6 rotations, significantly reducing the carbon footprint compared to single-use boxes (80 % reduction for transport distances of 50 km, the benefits being also positive for longer distances of up to 1000 km) and with different types of transportation. Last but not least, reusable transport packaging can accommodate a large percentage of recycled material in their composition without compromising integrity, further helping the development of a circular economy for materials.
In conclusion, reusable transport packaging stands as a proven solution embraced by forward thinking companies across various sectors. With established norms ensuring safety and functionality, coupled with its significant positive environmental impact, the case for its widespread adoption is compelling. It is already seamlessly integrated into supply chains, spanning from industrial applications to food and ingredients, with tailored collection and cleaning processes in place. Current reusable transport solutions widely available on the market are not patent protected, which means production can easily scale up to quantities needed once their use is encouraged by legislation. The infrastructure also exists and can be easily scaled as the technology is available.
