ORLEN S.A. position in the European Commission's consultation on the delegated decision introducing exemptions from reuse obligations for pallet wrappings and straps

The current wording of Article 29 of the PPWR imposes an obligation on companies operating in a single Member State or between associated companies in the European Union to ensure that by 2030, 100% of pallet packaging and strapping is suitable for reuse within a reuse system.

The ORLEN Group presented its position that, for technical, operational and economic reasons, the above-mentioned packaging formats should be completely excluded from all reuse targets.

Specific demands of the ORLEN Group:

• There are no real alternatives on the market to plastic pallet packaging that would be equally lightweight and ensure maximum safety, load stability, protection against rain and sun, and adaptability to all formats.
• Risk of disruptions in supply chains and the need to use inefficient solutions due to the lack of industrial-scale availability of reusable pallet packaging before 2030.
• Compliance with the obligations of Article 29 of the PPWR means huge additional expenditure resulting from the need to operate two parallel systems (single-use pallet packaging and reusable packaging). Reusable packaging requires manual handling, which leads to significantly lower efficiency compared to automated single-use systems, increased labour requirements and greater operational complexity. Strict requirements in the absence of automated reuse solutions lead to a loss of operational efficiency.
• Reusable pallet packaging requires the use of heavier and less flexible products, leading to a poorer environmental impact due to increased transport costs, higher fuel consumption and thus emissions, and declining logistics efficiency.

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