Basing the European Green Deal’s aspirations for packaging and circularity on evidence and facts

The fibre-based packaging industry is a key contributor to the European Green Deal’s aspiration to build a strong, circular and resource-efficient European economy. At Fibre Packaging Europe, we collectively represent a sector that is both highly sustainable and economically important: we employ more than 365k people in Europe and generate around €120bn in annual turnover.

As winter approaches and the war in Ukraine continues, high energy prices are putting pressure on Europe’s businesses and households. We need to keep the European Green Deal on track to maintain Europe’s resilience during challenging times like these

Looking at global news, product circularity and sustainably managing our natural resources remain high on the agenda, as world leaders meet at the COP27 climate summit this month. The hosts aim to base discussions on “the most reliable, credible science available” and move forward with concrete actions.

At Fibre Packaging Europe, we believe the same applies to EU policies. To be effective, they must be based on reliable, credible science. This rings particularly true for the packaging sector, as we look forward to the upcoming revision of the Packaging and Packaging Waste Directive (PPWD). We now understand that, as part of this review, the European Commission will propose the legislation as an EU Regulation (PPWR). As such it will immediately, equally apply in all EU Member States after finalisation of the legislative procedure.

The existing Directive is already central to promoting cost-effective circular economy principles across our industry. The upcoming PPWR is a fantastic opportunity to enhance these aims, further driving the circular economy and contributing yet more towards the European Green Deal’s objectives. To do so, the review must take the available scientific evidence into account. Any requirement adopted without robust evidence could trigger adverse effects that harm the environment, the health and safety of consumers and our economy.


The Packaging and Packaging Waste Regulation: getting the revision right


So how to get the revision right? We believe this must start with a recognition of the important role fibre-based packaging plays, its high recyclability and its unique position as a packaging form that is almost wholly derived from renewable sources.

Fibre Packaging Europe represents associations whose members’ products are sourced, manufactured, used and recycled in Europe using European technology. These products are highly recyclable and come from sustainably managed forests, replacing products based on finite fossil feedstock. Europe’s forest sector has a positive climate effect, mitigating 20% of the EU’s annual carbon emissions.

On recyclability, we lead the way. fibres from packaging were used 6.3 times on average in 2018. Several scientific studies show that paper fibres used in carton and cardboard packaging can be recycled 25 times or more while still retaining their quality.


Avoid the environmental, health and economic risks


As a sector, we also lead the way on recycling rates, with 82% of fibre packaging being recycled. In volume terms, this is more than all other packaging types combined, from glass jars to plastic bottles.

To understand our position, one must also take account of the primary function of the packaging: it protects goods throughout the logistics chain and on the shelf. Packaging preserves the product content, maintains a high standard of food hygiene and minimises food waste. Also, it can easily provide essential product information, from allergens to use-by dates.

In order to serve its purpose, our packaging may sometimes need to be coated, laminated or treated to meet these functional requirements. But this does not mean that fibre-based packaging is not recyclable. Innovation and developments continue to ensure that essential barrier layers have no effect on the recyclability of the packaging. The industry has developed guidelines1 to facilitate the circularity of fibre-based packaging, focusing on characteristics to be considered from the design phase.

As design for recycling guidelines guarantee that fibre-based packaging is recyclable by design, we warn against possible ‘negative lists’ for paper and board packaging, without solid science to back up items on that list.

Restrictions or bans on certain packaging types would fail to take into account the recyclability of the product, and could result in cases where sustainable fibre-based packaging is unnecessarily replaced by fossil-based sources like plastic or glass. This would trigger an increase in the carbon footprint and lead to lower recycling rates.

Such differential treatment also contradicts the principles of equality and non-discrimination found under the EU treaties and would be disproportionate in light of the European Green Deals’ objectives.

To maximise sustainability while remaining proportionate, the PPWR must ensure a robust, evidence-based definition of recyclability that is applicable to all packaging. This can first be achieved if it follows a material specific approach: taking account of the function of each type of packaging, for the reasons outlined above.

Second, the approach must be ‘technology-neutral’: we are an innovative sector that is focused on enabling a transition from fossil alternatives to sustainable fibre packaging. We work together across the sector on innovative packaging, recycling technologies and infrastructure. Policy should reflect and support these activities, not dictate the technology to be used or constrain new ideas.


Follow the facts


When it comes to scaling up product reuse models, our sector has major concerns over the prevailing view that reuse would always be better for the environment.

To be effective, the PPWR must follow the evidence: setting up mandatory targets for reuse could hinder fibre-based innovation, decrease the potential for substitution, cause major structural changes in the supply chain and pose an existential threat to parts of the fibre packaging industry.

It could also pose a risk to consumer health: reuse targets could increase the risks of cross-contamination due to multi-location cleaning, sanitation, storage and transport. Fibre-based single-use packaging can, on the contrary, ensure safety and that food stays fresh longer than when it is stored in reusable plastic crates, in turn reducing food waste.

Evidence supports the view that reuse is not necessarily the most beneficial environmental option for packaging. According to the results of an in-depth and certified Life Cycle Assessment (LCA) study conducted by Ramboll2, the reusable system in quick service restaurants generates 2.8 times more CO2-equivalent emissions, leads to 3.4 times more fossil resource depletion, consumes 3.4 times more freshwater and generates 2.2 times more fine particles compared to the fibre-based single-use system.

The extra logistics involved can also result in additional costs for food service systems. In contrast, fibre-based, recyclable single-use packaging sourced from renewable materials adds value for forest owners and the paper industry, providing additional incentives to plant new trees and supporting sustainable forest management.

An additional LCA study3 found that corrugated fibre-based boxes outperform reusable plastic crates for transporting food in 10 out of 15 impact categories, from climate change to resource and water use. In other words, in both cases, reuse is bad for the environment and does nothing to mitigate climate change.


Solid, evidence-based approaches: a must


Life Cycle Assessment (LCA) studies are helpful because they ensure a level playing field for the packaging sector. They follow a material-based, technology-neutral, and non-discriminatory approach. By taking account of the full life cycle of a product, LCAs can more accurately measure their environmental performance up to the end of the product’s life.

When it comes to ensuring that all packaging is reusable and/or recyclable by 2030, we support ‘Design for Recycling’ (DfR) guidelines, which also follow a strong evidence-based approach in defining the recyclability of packaging material. DfR guidelines consider the packaging composition, functionality and suitability for recycling in existing streams and with existing technologies.

Recent examples include the Paper-Based Packaging Recyclability Guidelines4 developed by the paper and board recycling, manufacturing and converting industry, and the 4evergreen alliance’s Design Guideline for Fibre-Based Packaging. The guidelines include assessments of the recyclability of used paper-based packaging in the collection, sorting and recycling processes. The industry is currently working on more specific guidelines for other fibre-based packaging products.

Great recycling starts with great collection of packaging. A core focus for us is the divergence of collection systems to ensure paper and board is always collected separately from other packaging types. It is essential that EU Member States adopt clear collection targets so that our industry can meet its recyclability goals.

Finally, the PPWR should consider more ambitious collection targets: a higher target of 90% for fibre-based packaging could lead to more predictable, reliable collection volumes and flows, in turn leading to an increase in recycling investments.

As with all our recommendations, we see more and more that actions are most effective when they follow the evidence. We look forward to discussing these policies as they progress in the weeks and months ahead.


About Fibre Packaging Europe


Fibre Packaging Europe is an informal coalition of seven trade associations representing industries involved in forestry, pulp, paper, board and carton production and recycling from across Europe. Our joint mission is to provide renewable, circular and sustainable fibre-based packaging solutions to European citizens to achieve the European Green Deal objectives.


For more information:



1 Circularity by Design Guideline for Fibre-Based Packaging (, 2022)

2 Ramboll life cycle analysis highlights the environmental benefits of single-use paper-based packaging (EPPA, 2022)

3 Recycling vs Reuse for Packaging: Bringing the science to the packaging debate (FEFCO, 2022)

4 Paper-based packaging recyclability guidelines (CEPI, 2022)