Finat and Afera publish release liner PPWR position paper

Finat and Afera have jointly published a position paper on the treatment of release liners under the EU Packaging and Packaging Waste Regulation, arguing that release liners used in self-adhesive products should not be classified as packaging under Regulation (EU) 2025/40.

The paper sets out that release liners perform an essential technical function and form an integral part of the product rather than functioning as packaging. It 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 packaging definition.

Finat and Afera are calling for a harmonized interpretation across EU member states to prevent divergent national approaches and unnecessary obligations under packaging and extended producer responsibility legislation. The paper is intended to support policymakers, national authorities and Producer Responsibility Organizations in consistent PPWR implementation.

The position paper is available to download via the Finat website.