Fibre Packaging Europe is calling on EU policymakers to build the next stage of the circular economy around systems that already work, particularly Europe’s established paper and cardboard recycling model. As the European Union prepares the upcoming Circular Economy Act, the paper-based packaging sector is urging legislators to prioritise harmonisation, ambitious collection targets and clearer Extended Producer Responsibility rules.

The debate comes as the EU packaging market prepares for the combined impact of the Circular Economy Act and the Packaging and Packaging Waste Regulation. Together, these policy files will influence packaging design, collection, recycling and producer obligations across a single market of more than 450 million consumers.

For paper-based packaging, the core request is simple: a circular economy framework must be clear, harmonised and predictable enough to support investment.

One of the industry’s main concerns is regulatory fragmentation. Packaging companies operating across Europe often face different national rules, reporting requirements and producer responsibility systems. This creates complexity, raises costs and can slow investment in recyclable packaging formats. Fibre Packaging Europe argues that the new Circular Economy Act should simplify this landscape by creating a more consistent framework for all Member States.

Separate collection is another key priority. Recycling begins long before material reaches a mill or recycling plant. If paper and cardboard are not collected separately and kept clean, the quality of recycled fibre decreases. For this reason, the sector is supporting an ambitious 90% separate collection rate across the EU, without derogations that could weaken implementation.

The paper and cardboard recycling chain is already one of Europe’s strongest circular systems. Consumers separate used paper-based packaging, municipalities and waste operators collect it, sorting systems prepare it, and paper mills turn the recovered fibre into new packaging. This creates a functioning loop that uses renewable and recycled materials while supporting high recycling rates.

Extended Producer Responsibility is also central to the discussion. EPR systems determine how producers finance packaging waste management, but rules currently vary across Member States. A more harmonised approach could improve transparency, ensure fees are reinvested into collection and recycling, and create stronger incentives for sustainable packaging design.

• Harmonised rules would reduce complexity for companies operating across EU markets.
• Higher separate collection would improve the quality of recycled paper and board.
• Clear EPR systems would support better financing of waste management infrastructure.
• Net-cost principles would ensure fees reflect actual recycling costs and material value.
• Proven circular models should be strengthened rather than disrupted.

The industry is particularly focused on how EPR fees are calculated. Fibre Packaging Europe argues that fees should reflect the value of secondary raw materials. This is important for paper and board because recovered fibre has strong demand in the European market and can be used again in new packaging. EPR systems should therefore avoid cross-financing between materials and respect the net-cost principle outlined in EU waste legislation.

For packaging producers, the Circular Economy Act could become a strategic opportunity if it delivers legal clarity. Companies need confidence before investing in new recycling capacity, design changes and collection partnerships. Unclear or conflicting rules can discourage investment and make it harder to scale circular packaging solutions.

The paper-based packaging sector also wants policymakers to recognise the difference between future ambitions and existing circular performance. While many packaging materials are still building effective recycling systems, paper and cardboard already operate through a well-established European loop. Supporting this model can help accelerate circularity while protecting industrial competitiveness.

At the same time, the sector will need to continue improving. Higher collection rates, better sorting, reduced contamination and more efficient recycling infrastructure will all be necessary as packaging volumes and regulatory expectations evolve. Circularity is not achieved only by choosing a recyclable material; it depends on the full system around collection, processing and market demand.

The message from Fibre Packaging Europe is therefore pragmatic. Europe should not redesign the circular economy from zero. It should strengthen the systems that already deliver measurable results and apply the same ambition to areas where performance remains weaker. For paper and cardboard packaging, this means clear EU rules, strong collection targets, fair EPR fees and recognition of recycled fibre as a valuable industrial resource.

As the Circular Economy Act moves forward, the packaging industry will be watching closely. The final framework will shape investment decisions, material strategies and recycling infrastructure for years. If the EU succeeds in harmonising rules while supporting proven circular models, paper-based packaging could remain one of the strongest pillars of Europe’s transition to a more resource-efficient economy.