EUROPE — The European Federation of Wooden pallet and Packaging Manufacturers (FEFPEB) fully supports the PPWR’s objectives to strengthen circularity and promote reuse.However, following our review of the work concerning wooden pallets, we have seriousconcerns that the current assessment does not adequately reflect how pallet reuse operates inpractice or provide a sufficiently representative basis for establishing a mandatory minimumnumber of rotations.  For the reasons set out in the attached statement, FEFPEB does not support the introduction ofa mandatory minimum rotation requirement for wooden pallets on the basis of the currentassessment. In particular, we believe that the evidence base and methodology should bereassessed, with meaningful involvement of the wooden pallet sector, before any suchrequirement is considered. Wooden pallets already operate within mature systems of repeated use, repair, reconditioning,and recycling across Europe. Their circular performance cannot always be captured through individual rotation counts.

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