JBCE’s FEEDBACK ON EXEMPTIONS FROM REUSE OBLIGATIONS UNDER THE DRAFT DELEGATED ACT ON PACKAGING AND PACKAGING WASTE (PLASTIC WRAPPINGS AND STRAPS)

08/01/2026

JBCE's Environment & Energy Committee has submitted its feedback on the draft delegated act regarding exemptions from reuse obligations for plastic wrappings and straps.

Key recommendations include:

・Clarifying the scope of exemptions and conditions for application

・Taking SMEs into account to prevent disproportionate impacts

・Supporting technological development and standardization for a sustainable transition

・Considering phased implementation

・Reducing reporting burden and digital one-stop-shop (OSS) platform

JBCE recommends that the delegated act be designed in a way that is practical, transparent, and consistent with circular economy objectives, while safeguarding environmental goals without imposing excessive burdens on the industry.

 

JBCE details its views and insights in its position paper, which can be downloaded below.

For more information please contact:

Shigeto Omae

Policy Manager

Environment & Energy

This email address is being protected from spambots. You need JavaScript enabled to view it.

Download document:

JBCE Position Paper