On October 21, the European Commission's Directorate-General for Environment announced the launch of a public consultation regarding "bio-based feedstock in plastic packaging."
This process, initiated under Article 8 of the Packaging and Packaging Waste Regulation (PPWR), aims to evaluate the technical development, environmental performance, feedstock sourcing, and production sustainability of bio-based plastic packaging, gathering evidence to inform potential future legislative measures.
According to the European Commission, the consultation is open to stakeholders across the entire value chain-including packaging manufacturers, processors, raw material suppliers, bio-based plastic producers, recyclers, companies involved in food-contact packaging, brand owners, retailers, consumer organizations, environmental NGOs, and research institutions. Feedback will be accepted until January 13, 2027. The Commission is required to complete its review of bio-based plastic packaging by February 12, 2028, and determine whether to propose new framework legislation.
The European Commission stated that increasing the use of sustainable bio-based feedstocks in plastic packaging could help reduce the EU's reliance on imported fossil-based resources, strengthen strategic autonomy, and lower the carbon footprint of the packaging industry-aligning with the EU's bioeconomy strategy. Under Article 8 of the PPWR, regulatory focus may develop along four key lines:
First, establishing sustainability requirements for bio-based feedstocks, ensuring that raw material sourcing and production processes comply with EU environmental standards.
Second, exploring the potential for setting targets for the use of bio-based feedstocks or bio-based content (currently, the PPWR does not mandate a specific bio-based proportion for plastic packaging).
Third, investigating whether bio-based plastics could serve as an alternative to meet certain recycled-content requirements, particularly for food-contact packaging where recycling technologies are currently limited.
Fourth, further clarifying the legal definition of "bio-based plastics"-defining them based on their raw material source, while distinguishing them from "biodegradable plastics."
Industry observers note that this signals an expansion of EU packaging regulation: moving beyond a focus on "recyclability" and "recycled content" toward the "sustainability of raw materials." For Chinese exporters of bio-based materials, biodegradable materials, and food-contact packaging, key areas to monitor include methodologies for calculating bio-based content, raw material traceability, evidentiary chains regarding land use and carbon footprints, and the compliance boundaries applicable to food-contact applications.
The European Commission has emphasized that the current consultation process remains in the stage of policy assessment and evidence gathering; no new mandatory standards have yet come into effect. However, the consolidation of feedback in 2027 and the review conclusions expected in 2028 will directly shape the design of the next round of "green" regulatory barriers for packaging in the European Union.
