Our position regarding the PPWR

Mosca welcomes the Packaging and Packaging Waste Regulation (PPWR). Its aim of promoting recycling and optimizing the use of resources is in line with our own long-standing commitment to more sustainability at the end of the packaging line. Regarding the reuse of plastic pallet wrapping and strapping material, the EU Commission has guaranteed an exemption via a delegated act. This offers planning security in the areas of transport packaging and load securing to companies and consumers alike.

We listed up the most important Q&A for you:

  • What is the packaging and packaging waste regulation (PPWR)?

    The PPWR is a new regulation adopted by the Commission of the European Union, often referred to as the EU Packaging Regulation in the media. It governs the handling of packaging within the European Union and requires EU member states to reduce their CO2 emissions caused by packaging. To reach this objective, the PPWR has set the four goals Replace, Reduce, Recycle and Reuse.

  • What is Mosca's position on the PPWR?

    We welcome and support the principles of the PPWR as we have been actively pursuing more sustainable materials and technologies at the end of the packaging line for many years. Accordingly, the PPWR’s aim to promote recycling and optimizing the use of resources is in line with our own philosophy and our goals for a more sustainable future, such as the development of a circular economy for strapping materials.

  • What is the current status of the PPWR & what will happen next?

    The European Parliament and the Environment Council adopted the PPWR on April 24. The text is now being reviewed by legal experts and translated into the respective languages of the member states. At the end of 2024, the newly elected EU Parliament will vote on the final version of the PPWR, which will enter into force in mid-2026 if approved. However, the EU Commission can issue delegated acts that allow exceptions to the objectives and requirements defined in the PPWR.

  • What does the PPWR in its current form entail for end-of-line packaging?

    On the one hand, the PPWR requires a minimum percentage of recycled content in plastic packaging, which our strapping materials already satisfy. We are also constantly striving for a higher percentage of recycled materials in our other consumables and we are working hard to meet the required quotas.

    On the other, Article 29 (new, previously Article 26) of the PPWR currently also specifies reuse quotas for pallet wrapping and strapping. We, along with experts from leading groups such as the VDMA and the German Plastics Industry Association, view these quotas critically, as they are neither technically nor ecologically feasible.

During the first reading in the European Parliament (EP), the EU Commission issued a clear statement on the planned exemption of stretch wrapping film and straps from paragraphs 2 and 3 of 29 (new, previously Article 26). According to Commissioner Sinkevičius:

“In the light of the concerns and calls for action, the Commission will launch an assessment of this issue by the end of this year and address it as a matter of priority upon the entry into force of the Regulation. To this aim, the Commission will adopt without delay a delegated act to exempt plastic pallet wrapping and straps …”

  • Why isn't the reuse of strapping or stretch wrap film feasible?

    Straps and stretch wrapping film are cut when they are first removed and cannot be reused for the same purpose without being recycled in an intermediate step. If the strapping and film were directly reused, it would pose safety risks during transportation. Other means of securing goods for transportation, such as wire boxes and crates, do not constitute sensible alternatives, either ecologically or economically.

  • How has the EU Commission responded to criticism of the reuse quotas?

    In an official letter, the EU Commission acknowledged the concerns and objections from the packaging industry and pledged to draw up a delegated act immediately after the PPWR’s ratification at the end of 2024. This will exclude the two types of material from the reuse quotas.

  • What does the PPWR mean for you as a Mosca customer?

    The European Commission has promised to issue a delegated act for plastic pallet wrapping and strapping that exempts both types of material from the specified reuse quotas. This exemption gives you planning security and the certainty that strapping and wrapping your products will continue to be permitted in the future. We already fulfill many of the other requirements defined in the PPWR. For example, our PET strapping is already made entirely of recycled material. We are also in the process of developing a circular economy to ensure the recyclability and actual recycling of our consumables.

    Of course, we will keep you informed of all new developments regarding the PPWR and its effects, whether in personal discussions or via channels such as our customer magazine.

  • Will you still be allowed to strap or rewrap your products in the future?

    Yes, the European Commission has promised to adopt a delegated act that excludes plastic pallet wrapping and straps from the reuse quotas defined in the PPWR. Strapping and wrapping will therefore remain a reliable way of protecting goods in accordance with the Transportation Security Act, which will remain in force.

  • How is Mosca pursuing and promoting sustainability and the circular economy?

    We have been committed to greater sustainability in end-of-line packaging for many years. Our efforts include using strapping as minimal packaging, the extensive application of recycled materials, and working to develop a comprehensive, closed circular system for recycling our straps.

Please read more about our comprehensive commitment to sustainability and environmental engagement.



Many organisations, associations and federations have requested the EU institutions to correct the original proposal of the EU packaging and packaging waste regulation (PPWR) on
the re-use quotas for industrial packaging, including pallet wrapping and strapping. With success: In the plenary, Commissioner Sinkevičius explicitly confirmed that the Commission will submit a delegated act in time, which will exclude pallet packaging from the scope of Article 29, paragraphs 2/3 of the Packaging and Packaging Waste Regulation. Here, you can listen to the relevant section of the Commissioner's speech from the plenary session. We have summarised the most important activities for optimising the original PPWR draft in the following sections.

PPWR law

Current proposal of the Packaging & Packaging Waste Regulation

EU Commission consent

Affirmation from Virginijus Sinkevičius, EU Commissioner
Letter to Ms Ries, MEP
Letter to Mr Liese, MEP

Response from EEP Group

Notifications & petitions

VDMA notification
Letter of German Associations
EUMOS position paper
EUPC customer notice
Expert Assessement Neumann petition

Charts & Guides

Overview of drastic expansion of re-use quotas for certain transport and sales packaging

Europen: PPWR Survival Guide

Mosca's road to the future!
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