Bio-based plastic packaging under PPWR: EU study sparks debate over recyclability & toxicity

The Publications Office of the EU has published a study co-authored by the German Nova Institute concluding that bio-based plastic packaging can support the climate-neutrality goals of the Packaging and Packaging Waste Regulation (PPWR). 

In response, advocacy groups ECOS, Rethink Plastic Alliance, Fern, and the Environmental Paper Network have addressed a letter to the European Commission’s Directorate-General for Environment (DG ENV) calling for alignment between the EU’s bio-based plastics policy and its circular economy objectives. 

Discussing the role bio-based plastics will play in the PPWR framework, as well as the EU Circular Economy Act, Michael Carus, founder of the Nova Institute and co-author of the study, tells Packaging Insights: “DG ENV plans bio-based quotas for packaging in addition to recycling quotas. Bio-based plastics will play an important role in replacing virgin fossil carbon in packaging.”

Meanwhile, Samy Porteron, senior programme manager at ECOS, tells us: “Bio-based plastics may play some role in reducing fossil feedstock dependence, but their use must be conceived within an ecodesign approach that supports circularity goals of preventing waste first, and then reusing and recycling products.”

Michael Carus, founder of the Nova Institute.“Simple substitutions of short-lived and potentially unrecyclable plastic products with an equivalent bio-based version will not help prevent impacts from the production of those materials and end-of-life management.”

Bio-based potential 

The Nova Institute report, titled “Support for bio-based feedstock in plastic packaging analysis under the Packaging and Packaging Waste Regulation (EU) 2025/40,” analyzes the use of bio-based feedstocks in plastic packaging by considering technological developments and environmental performance.

The paper states that there are currently 17 commercially available bio-based polymers, representing around 1% of the global plastics market and 4–5% of the EU chemical sector’s biogenic carbon. Production capacity is concentrated in Asia with 55%, North America with 17%, and the EU 27+ Iceland, Liechtenstein, and Norway with 14%, the study outlines.

It further evaluates the feasibility of setting targets for the use of bio-based materials and their equivalence with recycled materials in packaging.

Carus comments: “In terms of technology, all 17 commercially available bio-based polymers can be recycled. The main issues are volume [which will increase with a quota] and economically feasible collection — separation can easily be achieved with modern systems [training].”

“Some bio-based polymers, such as bio-PE, bio-PP, and bio-PET, can be fully integrated into the recycling stream of fossil PE, PP, and PET. Some bio-based polymers can also go in the bio-cycle and be biodegraded in industrial or even home composting.”

He argues that the current systems to ensure responsible biomass sourcing “are very robust,” adding that the established systems available are: ISCC plus (market leader), REDcert2, RSB, Better Biomass. For specific feedstock sources, he points to Bonsucre (sugar) and RSPO (palm oil). 

Lauriane Veillard, chemical recycling and plastic-to-fuels policy officer at Zero Waste Europe.“To be on the safe side, only those ‘sustainable’ certified feedstock should be accepted.”

To prevent consumer confusion between bio-based, biodegradable, and compostable plastics, Carus says that there are labels from TÜV Austria (Brussels, Belgium) and Din Certco (Berlin, Germany).

Lauriane Veillard, chemical recycling and plastic-to-fuels policy officer at Zero Waste Europe, part of the Rethink Plastic Alliance, responds: “When suggesting that bio-based content could be the equivalent to recycled content, it can alter the incentives for a better collection, sorting, and recycling of waste as bio-based plastics are virgin materials, therefore not incentivizing the overall infrastructure.”

“Producing virgin bio-based plastic to meet recycled content will not divert plastic from its current final end-of-life treatment in Europe, where plastic remains mostly incinerated and landfilled, which should rather be recycled in line with the waste hierarchy. Recent Plastic Europe data on the state of plastics [shows] the fact that 70% of plastics is still being burned.”

Furthermore, the letter by the Rethink Plastic Alliance and supporting organizations to DG ENV argues that a study by the Nova Institute published by the EU “presents information from lobby groups as sources to develop policy recommendations.”

“The risk is that it could impact EU policies on packaging, waste, plastics, and circularity by making bio-based plastics appear better for the environment than they really are.”

Toxicity concerns

Samy Porteron, senior programme manager at ECOS.Rethink Plastic Alliance’s letter says that the Nova Institute’s study does not fully address pollution and chemical safety considerations associated with bio-based plastics.

“Research shows the toxicity concerns can be equivalent, as the issues are not with polymers themselves but the additives used which tend to be the same as for conventional plastics.”

Addressing concerns about microplastic pollution and hazardous additives in bio-based plastics, Carus says: “Bio-based plastics have a lower risk than fossil plastics and a much lower risk than mechanical recycling. Also in many cases bio-based additives are available.”

Previously, we spoke to Aimplas, Avantium, and Oceana about viable options for the end-of-life management of bioplastics, including composting, recycling, and reuse, as well as the potential role of bioplastics in reducing reliance on virgin plastics and greenwashing concerns.

As debate grows over greenwashing and unclear biodegradability claims, regulation and clear definitions are emerging as key.