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Stretch Film and the PPWR: Recycled Content, Reuse Quotas and Thinner Film Explained

Updated: 5 min readIvan Cvitkušić

Pallet stretch film is covered by the Packaging Regulation (PPWR) in several places. As non-contact-sensitive plastic packaging, it generally needs 35 % post-consumer recycled content from 2030 at the earliest, pallet wrap and strapping are expressly named in the reuse quotas under Art. 29, and its weight must be reduced to what is necessary for its function. Anyone who buys or uses film should therefore look at recycled-content proofs, film thickness and load securing together.

Why stretch film falls under the PPWR

Pallet wrap is part of transport packaging: it holds load units together and protects the goods during handling and transport. The requirements of Regulation (EU) 2025/40, applicable since 12 August 2026, therefore apply to it, such as the substance restrictions under Art. 5 and the conformity assessment with technical documentation and an EU declaration of conformity for the packaging. Further obligations apply from 2030.

For manufacturers in Bosnia and Herzegovina and Serbia, this becomes relevant as soon as palletized goods are shipped to customers in the EU, because the film is placed on the EU market together with the goods. In Croatia the regulation applies directly. For an overview of cartons, pallets and film together, see the guide Transport packaging and the PPWR. This guide covers the details on film.

Recycled content under Art. 7

Plastic parts of packaging must contain a minimum share of recycled content from post-consumer plastic waste. Stretch film that is not contact-sensitive generally falls under “other plastic packaging”:

  • 35 % from 1 January 2030 or three years after the implementing act, whichever is later
  • 65 % from 1 January 2040 (fixed date)

Three points are decisive for purchasing:

  • Post-consumer: Only recycled content from plastic waste after use is counted. A general statement such as “contains recycled material” is therefore not enough.
  • Average per plant and year: The share is calculated as an average per production plant and year. What matters is therefore the data of the manufacturer’s plant, not just the data sheet of a single film.
  • Exemptions: Exempt are, among others, compostable plastic packaging, packaging for the transport of dangerous goods and plastic parts that make up less than 5 % of the packaging’s total weight. Whether an exemption applies should be checked case by case and not assumed too quickly.

Pallet wrap and strapping in the reuse quotas (Art. 29)

For transport packaging, Art. 29(1) expressly names flexible formats, pallet wrap and strapping as well. From 1 January 2030, economic operators who use such packaging within the EU must use at least 40 % of it as reusable packaging in a reuse system. From 2040 they are to aim for 70 %, which is a target value, not a fixed obligation. Between a company’s own sites, between linked or partner enterprises, and for deliveries to another economic operator in the same Member State, this packaging must be reusable.

Exempt are, among others, packaging for dangerous goods, made-to-measure packaging for large machinery, equipment and goods, and flexible formats in direct contact with food and feed.

In practice the question is how single-use film fits into a reuse system. Reusable load-securing solutions are conceivable, but whether they suit your goods and transport routes depends on the individual case. For suppliers outside the EU: how Art. 29 affects your deliveries depends on roles and contracts and should be clarified with the customer.

Thinner film without risk to load securing (Art. 10)

By 1 January 2030, manufacturers and importers must ensure that the weight and volume of the packaging are reduced to the minimum needed for it to function (Art. 10(1)). The function of stretch film is load securing. Using less film is only a gain if the load unit remains stable, because damaged goods create new waste and costs.

Starting points are:

  • film thickness and film type suited to the weight and shape of the load
  • pre-stretch, wrapping pattern, number of wraps and overlap
  • interaction with strapping, edge protection and top sheet

Changes should be tested and documented with real load units. The documentation also shows why a particular amount of film is necessary for the function.

Recyclability (Art. 6)

Packaging must be recyclable. Criteria for design for recycling apply from 1 January 2030 or 24 months after the delegated acts, whichever is later, with performance grades A to C as the minimum standard. From 1 January 2038, only grades A and B are permitted. The exact criteria are set by the delegated acts. Ask your supplier now about the material composition, additives and printing of the film.

What to ask your film suppliers

Question Why it matters
What is the post-consumer recycled content per production plant and year? Art. 7 is based on this average
How is post-consumer recycled content distinguished from other raw materials? Only post-consumer waste counts towards the quota
Which documents prove the share and its origin, and how often are they updated? EU customers ask for traceable proofs
Is there a supplier declaration on substances under Art. 5? Applies since 12 August 2026
Which film thicknesses and pre-stretch values suit our loads? Minimization without loss of load securing
How is the supplier preparing for the recyclability criteria? Art. 6 becomes stricter in 2038

Important: the film supplier’s declaration refers to the film. It is not automatically a declaration of conformity for the entire load unit made up of pallet, cartons, film and strapping. How to file such information in an orderly way is shown in the guide Documentation of packaging materials.

Practical steps

  1. Record consumption: note film types, thicknesses and quantities per load unit.
  2. Consolidate the range: fewer film types simplify purchasing and documentation.
  3. Obtain supplier data: put the questions from the table in writing.
  4. Test wrapping parameters: check thinner film or other settings with real loads.
  5. Clarify reuse: discuss with EU customers whether and how Art. 29 affects your load securing.
  6. Review alternatives: compare films with demonstrable recycled content. Our supplier network helps with this.

Review your stretch film now

Most obligations for stretch film take effect in 2030 at the earliest, but supplier changes and tests of wrapping parameters take time. Our packaging optimization combines load securing and material use, and the PPWR and EU compliance service maps the requirements to your packaging. If you want to know where your load securing stands today, request an initial assessment.

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