Industrial adhesive process films under PPWR
How a constructive dialogue creates greater regulatory clarity
Industry association work has always been an important element of our stakeholder dialogue. That today it is about far more than networking alone is demonstrated by the example of the market leading surface protection film specialist POLIFILM PROTECTION. Through close cooperation with other major players in the industry under the umbrella of AFERA (The European Adhesive Tape Association), a constructive dialogue with the European Commission helped achieve a crucial differentiation between process films and packaging films. This distinction is a key factor in determining the scope of the PPWR for industrial process films and, consequently, the potential future impact on both their manufacturers and users.
Adhesive process films, […] are not considered packaging under article 3 (1) of the PPWR.
The clarification published by the European Commission now confirms (as of April 2026) that adhesive process films, when used to enable or facilitate manufacturing processes and remaining on semi-finished products until further transformation or assembly, are not considered packaging under article 3 (1) of the PPWR. This outcome resolves one of the major uncertainties that affected the relevant industrial sectors with regard to the PPWR and brings much-needed practical relevance to the regulatory framework.
At the same time, this case serves as an excellent example of how association work can create a unified and effective voice, helping to shape legislation in a way that reflects the realities of industry. By actively providing technical details and critically examining the facts of the case through industry experts—coordinated by AFERA—the balanced and practical interpretation of the regulation was initiated in the first place.
It is not about industry versus politics, but […] working jointly with stakeholders
Marco FilipponiCEO POLIFILM ITALIA S.r.l., and representatives of POLIFILM PROTECTION at AFERA.
´Market players must take responsibility together and engage at an early stage in order to help shape the regulatory framework.´ comments Marco Filipponi, CEO POLIFILM ITALIA S.r.l., and representatives of POLIFILM PROTECTION at AFERA. ´This also requires a willingness to shift perspective and to work constructively on the matter with those who would normally be competitors in the market.´ Filipponi highlighted, that this is not about industry versus politics, but about taking responsibility as an industry and working jointly with stakeholders at EU level to shape future conditions in a sustainable and balanced way.