Stretch-film dispute exposes PPWR responsibility gap

European Plastic Films has challenged the European Commission’s interpretation of stretch film under the Packaging and Packaging Waste Regulation, arguing that film supplied on a roll should be treated as packaging material until it is applied to a pallet. The disagreement could determine which company carries manufacturer obligations for one of the most widely used forms of transport packaging in European food and drink logistics.

The Commission’s updated PPWR Frequently Asked Questions includes an example stating that stretch wrap used to stabilise products on pallets can already be considered packaging when sold on a roll, even though the material is subsequently cut and wrapped around a specific load. Under that interpretation, the film producer may be treated as the packaging manufacturer.

EuPF, the sector group representing European plastic-film producers within European Plastics Converters, wants the example withdrawn and replaced. It argues that the producer supplies packaging material whose final dimensions and quantity are only created by the business operating the wrapping equipment.

Thomas De Meester, Head of EuPF, said: “A roll of film is raw material for a packaging operation, not a finished packaging.” The association’s case rests on the distinction between manufacturing the film and determining the final configuration in which that film performs its transport-packaging function.

Stretch film leaves the converter with known properties including thickness, width, roll length, tensile characteristics, and recycled content. It does not, however, have the final dimensions of the material around a pallet because those depend on the load being wrapped.

Application settings can alter the result substantially. Pallet dimensions, film gauge, pre-stretch ratio, overlap, number of revolutions, wrapping pattern, load stability, and machine settings determine how much material is ultimately used and the shape of the finished wrap around the unit.

EuPF argues that the operator controlling those variables is therefore creating the finished packaging. The Commission’s interpretation places more weight on the fact that the roll has already been produced for a packaging purpose before it reaches the wrapping station.

The difference has become operational rather than theoretical because the PPWR generally began applying across the European Union on 12 August 2026. Its rules allocate different responsibilities to manufacturers, suppliers of packaging materials, importers, distributors, and other economic operators.

EuPF points to Article 16, which establishes information obligations for suppliers of packaging and packaging materials. Its position is that stretch film on a roll fits that supplier category until another business uses the material to create the final transport package.

The association also draws an analogy with wrapping paper supplied separately to businesses and with other materials whose final packaging form depends on application. It wants the same approach extended to products such as shrink film, shrink hoods, adhesive and bundling tape, strapping, edge protection, interlayers, netting, and other transport-packaging materials supplied in continuous or unfinished form.

Packaging minimisation is one of the practical reasons the distinction matters. PPWR places requirements around reducing unnecessary packaging, but a film producer does not control every setting that determines how many grams of stretch film end up around a food manufacturer’s pallet.

A warehouse using excessive revolutions or an unnecessarily low pre-stretch ratio can consume materially more film without the converter changing the product it supplied. EuPF argues that shifting manufacturer responsibility upstream would separate part of the compliance duty from the operator making the decisive application choices.

Recyclability creates a similar question. The converter controls the formulation and properties of the film, but downstream operators may subsequently apply labels, adhesives, or other materials to the wrapped pallet. Those additions can influence how the final packaging behaves in collection and recycling systems.

The disagreement is complicated further by national implementation. EuPF cites a June interpretation developed by packaging registers and competent authorities from 16 Member States through the European Network of Packaging Registers, which treats stretch, shrink, and cling films as packaging materials where their final form arises during filling or wrapping.

If national registers continue to place responsibility on the wrapping operator while Commission guidance points towards the film producer, companies can face overlapping compliance decisions. A converter supplying rolls across several Member States may register defensively as a producer while its customers continue reporting the same material under national rules.

That creates the possibility of duplicate registrations, tonnage declarations, authorisations, and fees around one physical material stream. It also makes enforcement more awkward because a film producer may know how many tonnes it sold into a market but not the final pallet dimensions, wrapping programme, or destination created by each customer.

Food and beverage businesses are heavily exposed because stretch wrapping is routine at the end of production and warehousing lines. Finished cases, trays, sacks, bottles, cans, and cartons are commonly stabilised on pallets before entering distribution, with automatic wrappers adjusting film application around load geometry and transport requirements.

The Commission FAQ is guidance rather than the legal text itself, so the example does not settle every interpretation on its own. Companies nevertheless use Commission guidance to design compliance systems, while national regulators use their own reading of the regulation to determine registrations and reporting.

EuPF wants the FAQ example replaced with wording that identifies film on a roll as packaging material and the business securing the load as the manufacturer of the final packaging. It also wants that position reflected consistently in forthcoming Commission guidance.

The underlying regulation is intended to reduce packaging waste and clarify responsibility across the value chain. Stretch film has exposed how difficult that becomes when the product leaving one factory is material for a packaging operation that only acquires its final form in another. Until the Commission and national registers converge on one interpretation, food manufacturers and film suppliers will have to manage the compliance gap between them.