Could a pallet strap be reusable? Reading the EU packaging proposal's tests in 2023

In February 2023 the European Parliament and the Council are working through the Commission’s proposal for a Regulation on packaging and packaging waste, published on 30 November 2022 with its impact assessment on the Commission’s environment pages. For strapping, the headline sits in Article 26(9): economic operators using pallet wrappings and straps to stabilise and protect palletised products during transport would have to ensure that 10% of that packaging is reusable within a system for re-use from 1 January 2030, and 30% from 1 January 2040.

The percentages are the easy part. The harder question is what a reusable strap would actually be. The draft answers it in three places: the conditions for reusable packaging in Article 10, the obligations on systems for re-use in Article 24 and Annex VI, and the counting rules in Article 27. Read together, they describe a managed loop rather than a stronger strap. All of it can still change during negotiation.

The Article 10 test, read against a strapping system

Article 10(1) lists conditions that packaging must meet together to be considered reusable. Paraphrased, and set against strap and closures:

Condition in the draft	What it would mean for strap and closures
Conceived, designed and placed on the market with the objective of being re-used	A strap bought as one-trip material does not become reusable because someone keeps it
Designed to accomplish as many trips or rotations as possible in normally predictable conditions of use	Someone has to know, from evidence, how many trips a strap and closure can make in the application
Can be emptied or unloaded without damage that prevents re-use	The joint must open without cutting the strap; friction-welded and crimped joints are normally cut to release the load
Can be unloaded and reloaded safely, without risk to the people doing it	Release and re-tensioning need their own safe method
Capable of reconditioning under Part B of Annex VI	There must be a defined inspection, repair or withdrawal step
Meets the recyclability requirements when it becomes waste	End of life still matters for a strap designed to circulate

Article 10(2) adds that compliance would be shown in the packaging’s technical documentation. For strap, that points to written evidence of design intent and expected use, not a description on a sales sheet.

A strap cannot be reusable on its own

Article 24 would require economic operators that use reusable packaging to take part in one or more systems for re-use meeting Part A of Annex VI, and to recondition the packaging under Part B before offering it for use again. Article 3 defines systems for re-use as organisational, technical or financial arrangements that enable re-use in a closed or open loop.

The annexes to the proposal spell out what such a system needs. Every system would need a defined governance structure; rules accepted by all participants on the types and design of packaging allowed, handling, collection, storage and reconditioning; a system operator who checks that re-use is happening; and reporting rules giving access to data on re-uses, rejects and collection rates. A closed loop, where ownership does not change, would also need reverse logistics and participants obliged to take packaging back. Reconditioning under Part B covers assessing condition, removing damaged or non-reusable components, sending them to an appropriate recovery process and inspecting fitness for purpose.

For strapping, the practical reading is that the loop matters more than the product. A woven strap that leaves on an export pallet and is never seen again cannot help a business meet a reuse share, however durable it is.

How the share would be counted

Article 26 states that the targets are calculated over a calendar year. Article 27(3) would have each operator count equivalent units of each listed packaging format: those used as reusable packaging within a system for re-use, and those used otherwise. The detailed calculation rules are left to implementing acts, which Article 27(4) asks the Commission to adopt by 31 December 2028. Under Article 28, the first reporting period would be the calendar year starting on 1 January 2030.

Until those rules exist, nobody can say what one equivalent unit of strap is. A site can still begin by counting straps applied per pallet pattern and noting which flows ever return.

Questions to settle before calling a strap loop reusable

These are design questions for a packing engineer or buyer, not compliance steps:

• Which flows come back? Transfers between a company’s own sites, or regular runs to the same partners, are the realistic candidates for a closed loop. Export pallets rarely are.
• Can the joint open intact? Buckled woven or composite strap can be released and re-tensioned mechanically. Whether a used strap and buckle are fit for another trip is a matter for testing and inspection, not assumption.
• What retires a strap? Write rejection criteria before the first return: cuts, abrasion, contamination, a deformed buckle, or a strap shortened by repeated trimming.
• Who owns the strap between trips? Annex VI distinguishes closed loops, without a change of ownership, from open loops, where ownership changes along the way.
• How are trips recorded? A system would need data on re-uses and rejects, so the counting method has to be practical at a busy dock.
• Does the tool suit used strap? Re-tensioning a strap that has already been under load is a question for the tool supplier and a line trial.

Keep the joint under control

A rule aimed at packaging waste does not change the mechanics of a strapped load. A reused strap still has to hold the load for the whole journey, and a change of strap, closure or tool remains a system change: sample, line trial, transport check and a written record of what was accepted. Our guide to woven and PET strapping joints explains why the strap, closure and tool belong in one review, and the note on wire diameter and load ratings explains why a buckle’s dimensions are not evidence of how many trips it can make. Inspection on return can borrow from a receiving checklist.

Practical next step

YAKU’s catalogue includes galvanized and phosphated wire buckles, with woven strap on request. If you are studying a buckled strap loop for flows between your own sites, send the strap, buckle and tool details through the enquiry page. No reuse claim is made for any component; performance depends on the complete system and is on request.