To achieve the headline objectives set under the European Green Deal, systemic transformation is needed. This will affect how we live, what we eat, what we wear, how we stay healthy and how we travel. Material substitution, including the use of renewable wood-based materials instead of fossil-based alternatives, will be imperative in this transformation.1 The Commission has recognised that the bioeconomy can be a catalyst for systemic change and help to achieve the green transition.2 New ways of producing and consuming resources while respecting our planetary boundaries should be further explored in the push for more sustainable products. Recyclable materials from renewable sources, such as fibre-based packaging, should be recognised as building blocks of the new circular economy. Consequently, the Commission should differentiate between fossil-based primary raw materials and renewable raw materials. To achieve climate neutrality by 2050, fossil resources will need to remain in the ground and the emissions from sourcing and manufacturing all products must be reduced. As such, we recommend that renewability be included as a sustainability principle under the Sustainable Products Initiative in order for EU policy to promote the phasing out of fossil-based products by switching to a green renewable economy. 

Preserving the material value of extant products is crucial to achieve increased circularity. In 2020, 56.1 million tonnes of paper and board were collected and recycled in Europe, and paper packaging has the highest recycling rate among packaging materials, with 84.2% in the EU.3 The market for recycled paper and board as a secondary raw material is already well-developed in Europe. For example, corrugated cardboard packaging contains on average 89% recycled content.4 The existing market demand allows the industry to recycle paper and cardboard and reuse the fibre in industry segments where they are needed. Fibre-based packaging needs recycled fibres and a continuous flow of fresh fibres into the recycling loop. In this context, we strongly believe that the introduction of an EU-wide mandatory requirement for recycled content in fibre-based packaging would challenge an industry which already leads in recycling, as collected material would be artificially diverted to be used to certain products and regions, leading to secondary material shortages for other products or regions. An EU-wide mandatory requirement applied on fibre-based packaging would only increase transport-related costs and emissions by shipping waste materials across Europe which otherwise could be fully recycled at their source. Ultimately, mandatory requirements would inevitably constrain the market and reduce consumer choice. Paper and cardboard recycling would be better supported by further developing high-quality separate collection and sorting systems to further increase recycling rates. 

To be truly sustainable, products need to be sustainably sourced. EU legislation should therefore promote the use of sustainably sourced raw materials in products, including packaging. Fibre-based packaging originates from sustainably managed forests, guided by EU and national forest regulations, as well as market-based certification systems such as the Forest Stewardship Council (FSC) and the Programme for the Endorsement of Forest Certification (PEFC). Sustainable forest management is multifunctional and continuously strives to find equilibrium between for biodiversity preservation, climate protection and economic output. Thanks to sustainable forest management, Europe can proudly claim that it currently has more forest resources than it did a century ago, with the forest area in Europe growing by 19.3 million hectares over the last 30 years.5 Total wood harvesting in the EU accounts for less than the annual growth rate of forests, thereby actively increasing the carbon stock of our forests and helping to preserve biodiversity. 

Different products serve different purposes and have different sustainability impacts. It is therefore important to recognise that a one-size-fits-all approach will not be effective in delivering the needed systemic change. For this reason, further product specific approaches should be addressed by dedicated legislative frameworks, such as the Packaging and Packaging Waste Directive (PPWD) for packaging. Care should be taken to avoid overlaps with duplicative legislation. 

By incorporating the SPI in a PPWD revision, we believe legislation can be clear, predictable and as easy to administer as possible. This would also secure long-term predictability, which is needed by industry to meet new requirements, make investments and drive new innovations. 

To minimise future external disruptions, secure global competitiveness and protect our prosperity, the EU must become economically, socially and environmentally resilient. The business community will be an important partner to achieve this.

Fibre-based packaging supports European resilience in several ways. It is sourced mainly from European forests and is recycled within Europe. It is produced across all parts of the continent, creating jobs and tax revenue, and it is sold to a large extent to European consumers.

Packaging plays an essential role in resilient and sustainable food systems, from ensuring consumer health and safety to increasing a product’s shelf-life and safety while reducing food losses and waste. Combined with its environmental benefits, these characteristics demonstrate that fibre-based packaging is an important contributor to Europe’s economic and social resilience. Policymakers should continue to recognise this contribution through a legislative framework which supports the industry’s ability to grow, invest and innovate. 

In an open and market-based economy, European products compete with products from the rest of the world. To be effective and secure a level playing field, it is critical that the overarching sustainability principles to be defined under the SPI are applied to both products produced in the EU as well as those imported from third countries.