Navigating regulatory changes: A tape industry perspective

Last update on Mar 12, 2025

The pursuit of a sustainable and circular economy is a constantly evolving journey. During this transition, enacting policies is essential in creating a level playing field. The European Commission adopted the new circular economy action plan and published the chemical strategy for sustainability in 2020.

Since then, a series of regulations and proposed rules has been handed down by the European Union. This affects the companies based or operating in the EU. Navigating this ever-evolving regulatory landscape can be quite challenging.

To support the needs of the European adhesive tape industry, the Regulatory Affairs Working Group (RAWG) at Afera and the European Adhesive Tape Association, keeps tabs on all the policy updates.

Having short-listed the topics which are of most relevance to the tape industry, the RAWG has created specific task forces to identify the main priorities. The outcome of the discussions within these task forces is shared regularly with the Advocacy Workstream of Afera's Flagship Sustainability Project (AFSP). This then proceeds to develop the related position papers and guidance documents.

Sustainability Communications Consultant, Sreeparna spoke to Pablo Englebienne, Regulatory Affairs Manager at Afera, who shared the latest developments in European policies and their impact on the adhesive tape value chain. Let's hear directly from them.

Task force origins & key topics in RAWG and AFSP advocacy workstream

SD: To start off, could you share how the creation of these specific task forces came about? Also, could you share some information on the other topics currently being discussed within the RAWG and the Advocacy Workstream of AFSP?

PE: We realized that the number of regulations within the European scope having an impact on the tape industry is expanding. The impact of certain topics is greater on some companies than others. There are many companies that are more actively following certain topics. The RAWG comprises a network of volunteers from Afera's member companies. They share knowledge and experiences for common benefit.

At Afera, we monitor the legislative developments. When we identify one that could have an impact, we specify – together with the members – what that impact may be and identify what we can do best to help our members and the sector as a whole.

The priorities were mapped out in 2024 and by surveying the participants, they identified seven aspects on which to focus.

Task force	Priorities identified
Packaging and Packaging Waste Regulation (PPWR)	Define which tapes and tape components are packaging and not Follow the development of the design of recycling (DfR) guidelines Understand the requirements of PPWR applicable to the general packaging of tape products Understand how PPWR impacts imported products
PVC REACH Restriction	Follow the development of the restriction Share information with members as it becomes available
Microplastic REACH Restriction	Share information on the responsibilities of tape manufacturers
EU Deforestation Regulation (EUDR)	Understand what are considered "relevant products" under the EUDR (raw materials and tape products) Provide guidance to members regarding steps to ensure compliance Liaise with authorities as needed
Green Claims Directive (GCD)	Understand the timeline for the legislative process, transition periods, and enforcement Understand the consequences for the tape industry, what to watch out for, and how to seek further assistance
Corporate Sustainability Reporting Directive (CSRD)	Exchange experiences and learnings from members on preparing for reporting
Corporate Sustainability Due Diligence Directive (CS3D)	Exchange experiences and learnings from members on preparing for reporting

Key priorities identified for topics of maximum relevance to the tape industry

Key takeaways from LCA and CSRD sessions at the 67th Annual Conference

SD: At last year's 67^th Annual Conference, the working program included interesting presentations on LCA and a detailed talk on CSRD. What were your key takeaways from these sessions?

PE: Indeed, Maria Pia Spinelli gave a great presentation on what LCA is all about. This was focused on how it relates to legislation such as the Eco-design for Sustainable Products Regulation (ESPR) and the proposed Green Claims Directive (GCD). My take-home message from her presentation was that LCA is no longer a 'nice to have', but a 'must do' for any type of product placed on the E.U. market.

Bastian Lehmann gave a detailed talk on CSRD, which was tailored to the supply chain and processes used in the adhesive tape industry. His presentation made attendees aware of the amount of effort required. This ranges from assessing the materiality of the impact of their operations to collecting all necessary information to prepare a report – to remain compliant with the requirements of the CSRD.

Collectively, these presentations highlighted how data and transparency are becoming increasingly important to demonstrate the sustainability of products to both consumers and regulators.

Regulatory landscape and timeline map

Major policy developments in European adhesive tapes industry

SD: Finally, could you provide us with a sneak peek into the expected policy developments and what the European adhesive tapes industry needs to watch out for in 2025 and beyond?

PE: In 2025, we will experience the following:

Further development and application of existing or ongoing legislation: Within this first category, quite a few developments are noteworthy:
- Even though the PPWR was just recently finalized, many details of its implementation will come in the secondary legislation (such as design for recycling criteria for packaging). The Commission will draft this over the next couple of years.
- We will also most likely see a proposal for a REACH restriction of PVC and/or PVC additives being drafted, as well as the development of other potential REACH restrictions being evaluated.
- The trialogues of the Green Claims Directive should be finalized in the coming months. This will then lead to its transposition into national legislation.
- The full implementation of the postponed European Deforestation Regulation is due at the end of 2025.

Development of a new working plan for the European Commission and Parliament: Concerning the future, the second von der Leyen Commission wants to focus on:
- Increasing the competitiveness of the European industry. A key aspect of this plan is the Clean Industrial Deal, which is due to be launched at the end of February 2025. This framework will include, among others, an Affordable Energy Prices Action Plan, an Industrial Decarbonization Accelerator Act, a Circular Economy Act, and a Chemical Industry Package.
- Within the latter, a review of the REACH Regulation will be produced. This will likely bring – among many other measures – a requirement to register polymer substances.

Afera, through actions within the RAWG and the Advocacy Workstream, will continue to monitor these developments and support the needs of the European adhesive tapes industry.

DISCLAIMER: All images and tables used in this article are copyright of Afera.