Can Bio-Based Plastic Count Toward PPWR Targets? The EU Opens a New Consultation
The European Commission has launched a new PPWR consultation on bio-based plastic packaging, open until 13 January 2027. Could renewable feedstocks play a role in future recycled-content requirements? We explain Article 8, the possible regulatory changes, and what packaging manufacturers, brands and suppliers should do now.
Can Bio-Based Plastic Count Toward PPWR Targets? The EU Opens a New Consultation
The European Commission has opened a public consultation on bio-based plastic packaging under Article 8 of the Packaging and Packaging Waste Regulation (PPWR). The consultation runs until 13 January 2027 and could influence future sustainability requirements, bio-based content targets and the relationship between bio-based materials and recycled-content obligations. Here is what businesses need to know.
A new development in EU packaging regulation
On 21 October 2026, the European Commission launched a public consultation titled Plastic packaging containing biobased feedstock – EU rules.
The consultation asks whether, and under what conditions, bio-based materials should play a greater role in plastic packaging placed on the EU market.
It comes at an important moment for European packaging policy.
Just one day later, on 22 October 2026, Eurostat published new packaging waste statistics showing that the EU generated an average of 35.9 kg of plastic packaging waste per person in 2024, of which 15.3 kg was recycled.
The EU's plastic packaging recycling rate reached 42.4% in 2024.
These figures highlight the scale of the challenge facing businesses and policymakers: reducing reliance on virgin fossil resources while improving packaging recyclability and material recovery.
The new consultation explores whether bio-based feedstocks could contribute to that transition.
For packaging manufacturers, importers, suppliers and consumer brands, the important question is not simply whether bio-based plastics are more sustainable.
It is how these materials may fit into the EU's evolving packaging compliance framework.
Read the official announcement: European Commission — Consultation on bio-based plastic packaging, 21 October 2026
1. What is the European Commission proposing?
Article 8 of Regulation (EU) 2025/40 requires the European Commission to review the technological development and environmental performance of bio-based plastic packaging by 12 February 2028.
Following that review, the Commission may propose legislation addressing four areas:
Sustainability requirements: Establishing criteria for bio-based feedstocks used in plastic packaging.
Bio-based content targets: Potentially introducing targets to increase the use of bio-based feedstocks.
Recycled-content flexibility: Considering whether bio-based feedstocks could, under specific circumstances, contribute toward certain PPWR recycled-content targets.
Definitions: Potentially revising the regulatory definition of bio-based plastic.
The third possibility is particularly significant.
Under Article 8(2)(c), the Commission may consider allowing bio-based plastic feedstock to substitute for post-consumer recycled content when suitable recycling technologies for food-contact packaging are unavailable, subject to the specific conditions described in the Regulation.
This is a possible future legislative change, not an exemption that businesses can rely on today.
The consultation itself does not amend the PPWR or create new mandatory bio-based content targets.
2. Bio-based, recycled, biodegradable and compostable: Why the distinction matters
These terms are frequently used interchangeably in packaging marketing, but they describe different material characteristics.
Term | What it means |
|---|---|
Bio-based plastic | Plastic made wholly or partly from biological feedstocks rather than fossil-derived raw materials |
Recycled plastic | Plastic made using recovered waste materials |
Biodegradable plastic | Plastic capable of biodegrading under specified environmental conditions |
Compostable plastic | Plastic designed to biodegrade under defined composting conditions, subject to applicable standards |
A bio-based plastic is not necessarily biodegradable.
A biodegradable plastic is not necessarily bio-based.
And neither term automatically means that a material contains qualifying post-consumer recycled content.
For example, a company may purchase bottles manufactured using bio-based polyethylene derived from renewable feedstocks.
The material may perform similarly to conventional polyethylene and may be compatible with existing recycling systems, depending on its formulation and the relevant waste stream.
However, the renewable origin of its feedstock does not, by itself, establish that the bottles contain post-consumer recycled plastic.
This distinction matters under the PPWR.
The European Commission's existing policy framework on bio-based, biodegradable and compostable plastics also emphasises that environmental performance must be assessed across the material's life cycle.
Renewable feedstocks are not automatically environmentally preferable in every application. Land use, sourcing, production, recyclability and waste management all matter.
3. Could bio-based plastics help businesses meet PPWR recycled-content targets?
Potentially, but only if future legislation establishes such a possibility.
Article 7 of the PPWR introduces minimum recycled-content requirements for specified plastic packaging categories, with the first targets scheduled for 2030, subject to the Regulation's implementation timing provisions.
These requirements focus on plastic recovered from post-consumer plastic waste.
Article 8 introduces a separate review of bio-based feedstocks.
The Commission may explore whether bio-based material could substitute for recycled content in certain food-contact applications where suitable recycling technologies are unavailable.
This would require further legislative action.
What does this mean in practice?
Consider a food-packaging manufacturer evaluating a new polymer formulation containing 30% bio-based feedstock.
That manufacturer should not assume that the formulation satisfies a 30% PPWR post-consumer recycled-content requirement.
Instead, it must distinguish between:
The percentage of bio-based material.
The percentage of qualifying post-consumer recycled content.
The relevant packaging category and applicable requirements.
The technical and regulatory evidence supporting each claim.
The proposed material must also be assessed against applicable requirements for food-contact safety, packaging recyclability and other relevant legislation.
The operational takeaway: Businesses should continue developing recycled-content compliance strategies under the current PPWR rules while monitoring possible changes to the treatment of bio-based feedstocks.
For a detailed explanation of Article 7, see our related article: PPWR Recycled Content Requirements: Why Preparing for 2030 Starts With Your Suppliers Today.
4. Why the consultation matters to brands and packaging suppliers
The Commission is seeking evidence from across the packaging value chain.
This includes packaging manufacturers, material suppliers, recyclers, food-contact packaging businesses, brand owners, retailers, researchers and other interested stakeholders.
For businesses already evaluating new packaging materials, the consultation presents an opportunity to contribute practical evidence before future legislative proposals are developed.
Several issues deserve particular attention.
Feedstock availability and sustainability
Can sufficient quantities of sustainably sourced bio-based feedstocks be produced at commercial scale?
Are suppliers using agricultural crops, forestry resources, industrial by-products or organic waste?
What documentation can substantiate feedstock origin, sustainability and traceability?
Packaging performance
Can bio-based materials meet existing requirements for product protection, barrier properties, shelf life and processing efficiency?
What testing or investment would be required to qualify alternative formulations?
Recycling compatibility
Can the material enter existing collection and recycling streams without negatively affecting the quality of recovered material?
Would dedicated collection or treatment infrastructure be necessary?
Commercial feasibility
How would new material requirements affect pricing, supplier availability, production capacity and implementation timelines?
These are especially important questions for businesses operating across multiple packaging categories or relying on a limited number of qualified suppliers.
The Commission is seeking evidence, not simply expressions of support for bio-based materials.
Well-documented operational experience could therefore be valuable.
5. What should businesses do before 13 January 2027?
Companies do not need to wait for a new legislative proposal to begin evaluating their packaging portfolios.
A practical starting point involves five activities.
First, identify relevant packaging materials.
Review packaging specifications to determine which products currently contain conventional virgin plastic, recycled plastic, bio-based plastic or combinations of these materials.
Second, separate material claims.
Ensure supplier information distinguishes bio-based content from recycled content, biodegradability and compostability. Avoid treating one claim as evidence of another.
Third, assess suppliers and evidence.
Identify the origin of feedstocks, manufacturing arrangements, available certifications, test results and any limitations affecting material traceability.
Fourth, evaluate technical and commercial constraints.
Document potential barriers involving production processes, food-contact suitability, performance, recycling compatibility, availability and cost.
Fifth, consider submitting evidence to the Commission.
Businesses with experience developing, purchasing, processing or recycling bio-based plastic packaging can use the consultation to explain what works, what does not and which regulatory approaches would be practical.
The objective is not to assume that all bio-based materials should receive preferential treatment.
It is to help develop requirements that are technically achievable, environmentally credible and supported by verifiable evidence.
Consultation deadline: 13 January 2027.
Participate through the European Commission's Have Your Say portal
6. What does this mean for existing PPWR obligations?
The new consultation does not change the obligations already applicable under Regulation (EU) 2025/40.
The PPWR generally began applying on 12 August 2026, with other requirements becoming applicable in subsequent phases.
Businesses must continue assessing their current obligations, including applicable restrictions on substances of concern, conformity assessment, technical documentation and traceability.
Future requirements concerning recyclability, recycled content, packaging minimisation and other measures remain relevant.
Organisations should therefore treat the Article 8 review as a potential development within their longer-term materials strategy, rather than as a reason to postpone existing compliance activities.
Frequently asked questions
Is the EU introducing mandatory bio-based plastic packaging targets in 2026?
No. The European Commission launched a consultation on 21 October 2026 to gather evidence that may inform future legislation. No new mandatory Article 8 bio-based content targets have been established through this consultation.
Can bio-based plastic count toward PPWR recycled-content targets?
Bio-based origin alone does not satisfy the existing Article 7 requirements for qualifying post-consumer recycled content. Article 8 allows the Commission to consider a possible future legislative route for certain food-contact packaging circumstances, but that possibility is not currently a general exemption.
Is bio-based packaging automatically biodegradable or recyclable?
No. Bio-based describes material origin. Biodegradability and recyclability are separate properties that depend on material composition, design, treatment conditions and available infrastructure.
When will the EU decide on new bio-based packaging requirements?
Article 8 requires the Commission to complete its review by 12 February 2028. Any subsequent legislative proposal would need to follow the applicable EU legislative process. The review deadline is not itself a deadline for businesses to adopt bio-based plastics.
Who can participate in the consultation?
The consultation is open to interested stakeholders, including packaging manufacturers, raw-material suppliers, brand owners, importers, retailers, recyclers, research organisations, consumer organisations and citizens.
When does the consultation close?
The European Commission has announced a closing date of 13 January 2027.
From regulatory developments to practical packaging decisions
The Commission's new consultation shows that the PPWR framework will continue to evolve as technologies, markets and packaging materials develop.
For businesses, the challenge is to manage two activities simultaneously.
They must implement the obligations that already apply while making informed decisions about materials, suppliers and packaging designs that may remain in use for years.
That requires more than monitoring regulatory announcements.
It requires reliable packaging data, clear supplier information and an understanding of how different requirements interact.
At PPWR Academy, our focus is helping businesses translate these regulatory developments into practical compliance and operational decisions.
Want to understand how the PPWR applies to your packaging portfolio?
Join our free PPWR Academy webinar to explore regulatory requirements, supplier information, compliance evidence and implementation priorities.
Register for a free PPWR Academy webinar
Official sources and further reading
European Commission — Bioeconomy: Commission launches public consultation on bio-based feedstock in plastic packaging, 21 October 2026.
Regulation (EU) 2025/40 — Packaging and Packaging Waste Regulation, particularly Articles 7 and 8.
Eurostat — Plastic packaging waste in the EU: 35.9 kg per person, 22 October 2026.
European Commission — Bio-based, biodegradable and compostable plastics.
Regulatory status: 2 November 2026. This article is provided for educational purposes and does not constitute legal advice. Regulatory requirements and proposed measures should be assessed against the applicable official legal texts and subsequent developments.
