The EU packaging regulation proposal of 30 November 2022: what it says about straps and pallet wrap

On 30 November 2022 the European Commission published its proposal for a Regulation on packaging and packaging waste. Much of the proposal deals with sales packaging. For anyone who buys or specifies strapping, the more striking detail sits in the transport packaging provisions: the draft gives pallet wrappings and straps their own reuse targets.

This is a proposal at the start of the EU legislative process. The European Parliament and the Council will examine and may amend it. What follows describes the text as published in November 2022 and what a strapping buyer can usefully do in December 2022.

What was published

The Commission’s DG Environment publication page, dated 30 November 2022, lists the proposal itself, its impact assessment and the supporting studies. The legal text is COM(2022) 677 final on EUR-Lex, under procedure 2022/0396(COD).

Because it is drafted as a regulation rather than a directive, the adopted text would apply directly in Member States instead of being transposed into national law. Dates and percentages in the draft are therefore worth reading carefully, even at this early stage.

The provisions that mention straps

Article 26 of the proposal sets reuse targets for different packaging formats. The parts most relevant to strapping are these:

Provision	Packaging covered	Proposed requirement
Article 26(7)	Pallets, plastic crates, foldable plastic boxes, pails and drums used for transport	30% reusable from 1 January 2030; 90% from 1 January 2040
Article 26(9)	Pallet wrappings and straps used to stabilise and protect products on pallets during transport	10% reusable from 1 January 2030; 30% from 1 January 2040
Article 26(12)	Transport packaging between an operator’s own sites, or with linked or partner enterprises	Reusable packaging required for listed formats such as pallets, non-cardboard boxes, trays, plastic crates, IBCs, drums and canisters
Article 26(13)	Deliveries to another operator in the same Member State	Only reusable transport packaging for listed formats such as pallets, non-cardboard boxes, plastic crates, IBCs and drums
Article 26(14)	Small operators	Exemption from the targets in paragraphs 2 to 10 for operators that place no more than 1,000 kg of packaging on the market in a calendar year, or that are micro-enterprises

Two points stand out. First, the reuse targets proposed for wrappings and straps are lower than those for pallets and crates. Second, in the text as published, pallet wrappings and straps are not among the formats listed in paragraphs 12 and 13, where reuse becomes mandatory for transport between an operator’s own sites or within one Member State. That could change during negotiations.

Recycled content for plastic packaging

Article 7 of the proposal introduces minimum recycled content for plastic packaging, recovered from post-consumer plastic waste. For plastic packaging outside the specific categories set out separately, such as contact-sensitive packaging and single-use beverage bottles, the draft proposes 35% from 1 January 2030 and 65% from 1 January 2040.

Plastic strap that counts as packaging and does not fall within those specific categories would appear to sit in the general category as drafted. The emphasis on post-consumer material matters: a recycled-content claim based on production scrap may not count in the same way. Steel buckles, clips and seals are not plastic packaging and are outside Article 7.

National measures already scheduled

Some Member States already have their own measures scheduled. Spain’s Ley 7/2022 on waste and contaminated soils, published in the Official State Gazette on 9 April 2022, creates a special tax on non-reusable plastic packaging at 0.45 euros per kilogram of non-recycled plastic. The law’s preamble sets 1 January 2023 as the start date for its tax measures. Buyers supplying into Spain should check how their strap and wrap are treated before that date.

What a reuse target would mean for a strapping system

Strap joints are commonly cut at the destination, and the strap is then discarded or recycled. A reusable strap would need a closure that can be opened without destroying the strap, a strap that survives removal and handling, and an organised loop that brings it back into use. Whether any particular system would count as reusable depends on definitions and criteria that the legislative process has yet to settle.

Woven and composite strap with wire buckles is one family that buyers may look at, because buckle joints can be opened and re-closed. That is a reason to examine it, not a conclusion. Any reused strap would still need to meet the joint and load requirements of the application, which our joint selection guide explains.

A December 2022 checklist

• Record the weight of strap and wrap per pallet pattern, by material.
• Record closures separately: steel buckles, clips and seals are a different material stream.
• Note which flows run between your own sites or stay within one Member State.
• Ask strap suppliers what recycled-content evidence exists, and whether it is post-consumer.
• Watch the legislative process, but do not change specifications or make compliance claims on the basis of a draft.

To discuss strap and closure options, share the application through the enquiry page. YAKU lists woven strap and PET strap on request, alongside galvanized wire buckles and steel strapping seals. Documentation is confirmed for the actual proposed supply.