How the EU Commission plans to regulate biobased feedstock in the PPWR

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Introduction

This edition of the Brief dives deeper into the European Commission’s analysis of biobased feedstock in plastic packaging to understand its potential role in the Packaging and Packaging Waste Regulation.

Key takeaways

The European Commission believes there are ‘no fundamental technical barriers’ to upscaling biobased plastics. Seventeen are already commercially available, many of them at Technological Readiness Level (TRL) 9 – the highest readiness level.

Scenarios for 2050 indicate that biobased plastics could account for 10-30% of plastic packaging, and the Packaging and Packaging Waste Regulation requires the Commission to publish a legislative proposal that defines and regulates biobased feedstock by 12th February 2028.

Biobased plastics are believed to lower carbon emissions by 30-70%. Some are thought to outperform their fossil-based counterparts; for example, PEF is believed to improve the barrier properties, mechanical strength, and temperature resistance of conventional PET. However, concerns have been raised about environmental trade-offs, including land use, eutrophication, and acidification. These can vary depending on how the biobased feedstock is sourced.

Production costs are generally higher for biobased plastics, and a lack of concrete structural policy has also led to an uneven playing field between global regions. Some have argued that using food crops as biobased feedstock creates competition with the food industry and call for restrictions, but the Commission believes that food crops are an essential resource in upscaling bioplastics due to their economic viability.

Existing certifications like ISCC PLUS, RSB, and FSC could be used to verify that biobased feedstock is sustainably sourced and doesn’t interfere with the food chain, but the Commission notes that certification requirements could become an additional burden on manufacturers when they already compete with fossil-based materials.

The Commission sets out ‘reasonable considered targets’ to achieve full defossilization by 2050 through the implementation of biobased and CO2-based plastics. It argues that food-contact PET should contain 24% biobased content, while other food-contact plastics should contain 44%. Single-use plastic drink bottles and other plastic packaging should contain 20%.

Using linear scaling based on data from 2024, the Commission suggests biobased content targets for different types of plastic. Food-contact PET could contain 24% biobased content by 2040; other food-contact plastics could contain 44%; and single-use plastic drink bottles and other plastic packaging could contain 20%.

Biobased and recycled content targets should complement each other, the Commission says. Each is thought to reduce dependence on fossil carbon and lower greenhouse gas emissions, with biopolymers unlocking specific advantages such as food-contact applications and avoiding toxic substances.

Looking ahead, the Commission argues that the Renewable Energy Directive III’s criteria could be adapted to suit biobased feedstock, while nova-Institute’s Biomass Utilization Factor metric could be used to measure ‘cascading use’, or the potential to maximize a raw material’s lifespan by harnessing residues and recyclate before the energy recovery stage.

Conclusion

Although the legislative proposal for biobased feedstock in the PPWR is yet to come, the Commission summarizes its vision as follows:

• Binding targets for biobased content in packaging, linked to sustainability criteria, to incentivize demand and investment;
• Regulation that equates recycled and biobased carbon content in a ‘systemic view’ on achieving carbon circularity;
• Harmonized sustainability criteria that build on the Renewable Energy Directive III and ensure ‘reliable transparency’ on biomass sustainability;
• Support to develop infrastructure for collecting and recycling biobased plastics, thus improving circularity and establishing synergies between recycling and biobased technologies;
• Promotion for R&D, especially upscaling to market, to lower costs and unlock innovative solutions.

Are bioplastics a viable contribution to the Packaging and Packaging Waste Regulation’s sustainability goals?

This edition of the Brief dives deep into the European Commission’s analysis of biobased feedstock in plastic packaging, detailing its current view of the benefits, restrictions, and questions surrounding bioplastic packaging laws.

Feasibility

According to the Commission, there are ‘no fundamental technical barriers’ to upscaling biobased plastics. The report observes that seventeen biopolymers are already commercially available.

Many of these existing biopolymers are thought to have reached Technological Readiness Level (TRL) 9 – the highest readiness level, in which the product in question is proven to be viable in practice. If the transition continues, the Commission believes that biobased feedstock could be a key factor in bringing down the EU’s carbon footprint and establishing a continent-wide circular economy.

Compared to fossil-based alternatives, biobased plastics are thought to slash carbon emissions by 30-70% and align with the EU’s decarbonization and circular economy goals. Biobased variations of polyethylene and polypropylene are said to unlock a negative carbon footprint when accounting for biogenic carbon uptake.

Some biopolymers are even believed to outperform their fossil-based counterparts. To name one example, the report claims that polyethylene furanoate (PEF) is 15x more resistant against CO2, 10x more resistant against oxygen, and 2.5x more resistant against water than conventional PET – and all these features are anticipated to extend the shelf life of packaged products.

Furthermore, PEF is said to increase mechanical strength and unlock thinner packaging designs, thus consuming fewer resources. It can also be processed at lower temperatures, withstand more heat, improve mechanical stiffness and broaden shaping possibilities, the report adds.

The Commission goes on to recommend biobased polymers for use in food-contact packaging – citing its ‘virgin quality’ and its adherence to food safety requirements. ‘Drop-in’ solutions like bio-PET and bio-PE are compatible with existing mechanical recycling processes. Other solutions can reportedly be separated using established sorting technologies, including NIR spectroscopy.

Even so, biobased polymers are said to represent just 1% of the global plastics market at present – and for all they are believed to save fossil resources and greenhouse gas emissions, other fears have emerged around their implications for land use, eutrophication, and acidification, which can depend on how the feedstock is sourced.

Structural barriers are slowing their growth, the report suggests. Production costs are generally higher for bioplastics than their fossil-based alternatives. While economies of scale and technological advancements are hoped to bring prices down in the coming years, bioplastic producers are currently competing with a well-established petrochemical industry; and the Commission points out the ‘chicken-and-egg’ scenario of a lack of end-of-life solutions versus a low incentive to invest in new recycling streams.

A lack of concrete structural policy has also led to an uneven playing field between global regions. Most of the world’s bioplastic production capacity is currently located in Asia, compared to a 17% figure in North America and 14% in the EU27+3 – but global capacities for biobased polymer production are expected to rise by 2030.

Of the 4.2 million tonnes of biobased polymers produced in 2024, 31% were derived from glycerol, 25% from sugars, and 20% from starch. Concerns have been raised that using food crops to manufacture bioplastics will create competition with the food industry, to which some parties respond that policymakers should enforce feedstock caps for non-food applications.

The Commission disagrees. It suggests that sugar, starch and other first-generation food crops are essential to the expansion of biopolymer packaging due to their economic viability.

Relying solely on mechanical recycling is also discouraged. Not only would recyclers struggle to process multi-layer packaging, the report argues, but a market consisting solely of mechanical recyclate may struggle with polymer degradation, contamination, and an overall scarcity of high-quality recycled plastic.

For these reasons, the Commission declares that bioplastics should not be excluded from feedstock-related policies, but the rules should avoid direct competition with food streams while ensuring ‘stringent’ certification to prevent deforestation and biodiversity loss.

Existing certification systems like ISCC PLUS, RSB, and FSC could be used to address all environmental concerns, from social implications to land use criteria. This certification, alongside feedstock diversification, is considered an important factor in mitigating trade-offs – but the report warns that it could become an additional burden for producers of biobased plastics as they try to compete with fossil-based materials.

In the long term, the Commission envisions the use of biowaste as a raw material to avoid crossover with the food chain. This would come with the added benefit that certified compostable packaging made from biobased materials could enter the biowaste stream at end-of-life, the report explains.

In general, though, the Commission recommends a ‘portfolio approach’ in which biobased feedstocks are used in tandem with recycled content and carbon capture and utilization. Complementarity between biobased and recycled content requirements may require adjustments to existing recycling infrastructure, but the report believes that implementing this equivalence into the Packaging and Packaging Waste Regulation would accelerate Europe’s efforts to transition to a circular, climate-neutral economy.

Targets

Scenarios for 2050 indicate that biobased plastics could account for 10-30% of plastic packaging, but explicit targets are not yet widespread. So far, the Commission itself aspires to ensure that at least 20% of carbon used in chemical and plastic products should come from sustainable non-fossil sources by 2030.

Under the Packaging and Packaging Waste Regulation, the Commission is also required to review the technological development and environmental performance of biobased plastic packaging by 12^th February 2028.

From this, it must present a legislative proposal containing sustainability requirements for biobased feedstock in plastic packaging; targets to increase the use of biobased feedstock in plastic packaging; and the possibility of packaging producers using biobased plastic feedstock to meet recycled content targets.

In general, the Commission believes that mandated compliance could signal demand and justify investment in certified supply chains – but setting the rules is more complex than it first appears.

The report identifies a ‘confidence gap’ in the systemic governance and market readiness of sustainability certification regarding biomass. Questions remain surrounding the recognizability of the major schemes and whether they should be harmonized. The scale and integrity of auditing processes are also debated – and all these considerations are important to clarify before targets are set for biobased content.

The Commission does assert that only biobased, bio-attributed, or natural fibres that can demonstrate sustainable feedstock certification should count towards content targets. Said targets should be developed based on the existing Renewable Energy Directive III criteria – including its goal of implementing at least 42.5% of renewables in Europe’s energy mix by 2030 – but further adapted to the relevant requirements.

Yet other clarifications are necessary. Should a bioplastic with the minimum amount of biobased content count in its entirety, or only be counted for its biobased content? Should bio-attributed plastics be included?

Regarding biocomposite materials, the report indicates that biobased quotas should account for both the plastic and natural fibre components, as the former can also be used to substitute fossil plastics in packaging.

The Commission also sets out what it describes as ‘reasonable considered targets’ to achieve full defossilization by 2050 through the implementation of biobased and CO2-based plastics. Based on the current recycling share of existing packaging formats and the projected upscaling timeline of CCU, it splits the remaining fossil share as follows:

Placing the share of bioplastics in the market at approximately 1% in 2024, the Commission uses linear scaling to suggest that biobased content targets could look like this:

Meeting these targets would first require the use of imported materials, the report specifies, with the share of domestic production increasing once Europe increases its capacity. This approach is thought to align more closely with net-zero targets,

Alternatively, an exponential growth trajectory could start slowly but accelerate rapidly. This could align with new investments for capacity building in new markets, the Commission suggests.

In any case, biobased and recycled content targets are expected to ‘principally complement each other’. Each is thought to reduce dependence on fossil carbon and lower greenhouse gas emissions, with biopolymers unlocking specific advantages such as food-contact applications and avoiding toxic substances.

As such, the report calls for an equivalence framework to boost industrial flexibility and resilience, and to ‘foster a technology-neutral approach for innovation and scaling’.

What next?

The Commission advises brands to embrace biopolymers, cultivate an eco-conscious image, and gain a competitive advantage. Yet, the report demonstrates that weaning the European packaging sector away from fossil fuels will require supportive policies, infrastructural developments – and, of course, a sustainable source of feedstocks.

The Renewable Energy Directive has already set out a framework to source biomass sustainably; this includes restrictions on high-biodiversity and high-carbon-stock lands. The Commission suggests that adapting these criteria for biobased plastics could establish consistency and credibility.

Other feedstock sources could include C1 gases from industrial emissions or non-food biomass like lignocellulose or waste products, but of course, their use in packaging is still in the early stages. The report also considers the ‘cascading use’ of biomass, or maximizing the lifespan of raw materials by harnessing residues and recyclate before the energy recovery stage.

Cascading use is described in the report as a ‘distinct and vital area’ with ‘limited’ practical implementation thus far. Said to result in a lower environmental impact than the direct generation of bioenergy, including CO2 emissions, the approach is set to reduce pressure to extract virgin resources from forests and agricultural land.

The Commission suggests that nova-Institute’s Biomass Utilization Factor (BUF) could be a useful metric to measure cascading use (how often biomass is used) and production efficiency (how much of the biomass is utilized) in a single indicator. If a material’s BUF is above 1.0, the biomass has been used more than once on average – and the report indicates that bio-PET in bottles can reach a BUF of 4.97.

“By adopting such clear metrics, we can move the concept of cascading use from a theoretical ideal to a measurable and implementable component of a sustainable bioeconomy,” the Commission writes.

According to the report, the early stages of commercial development for biopolymers will bring about key learnings and optimization opportunities; these are set to include more efficient and affordable approaches to existing fermentation, chemical, and enzymatic technologies.

To lessen industrial reliance on fossil-based packaging, the Commission sets out its vision:

• Binding targets for biobased content in packaging, linked to sustainability criteria, to incentivize demand and investment;
• Regulation that equates recycled and biobased carbon content in a ‘systemic view’ on achieving carbon circularity;
• Harmonized sustainability criteria that build on the Renewable Energy Directive III and ensure ‘reliable transparency’ on biomass sustainability;
• Support to develop infrastructure for collecting and recycling biobased plastics, thus improving circularity and establishing synergies between recycling and biobased technologies;
• Promotion for R&D, especially upscaling to market, to lower costs and unlock innovative solutions.

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