Afera and FINAT have jointly published a position paper on the treatment of release liners under Regulation (EU) 2025/40 on Packaging and Packaging Waste (PPWR). The paper explains why release liners used in self-adhesive products should not be considered packaging, as they perform an essential technical function and form an integral part of the product.

 

The paper further argues that release liners used in industrial and manufacturing processes meet the same criteria that led the European Commission to exclude adhesive process films from the definition of packaging. FINAT and AFERA call for a harmonised interpretation across the EU to avoid divergent national approaches and unnecessary obligations under packaging and EPR legislation.

 

The position paper is intended to provide aligned information along the supply chain and support policymakers, national authorities and Producer Responsibility Organisations (PROs) in the consistent implementation of the PPWR.