JBCE Feedback on Exemptions from Reuse Obligations under the Draft Delegated Act on Packaging and Packaging Waste

On 8 January 2026, JBCE submitted its feedback on the PPWR Draft Delegated Act regarding exemptions from reuse obligations for plastic wrappings and straps.

JBCE calls for:

• Clarifying the scope of exemptions and conditions for application
• Taking SMEs into account to prevent disproportionate impacts
• Supporting technological development and standardisation for a sustainable transition
• Considering a phased implementation
• Reducing reporting burden and digital one-stop-shop 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.

For more information, please contact info@jbce.org