A new analysis by nova-Institute for the European Commission argues that bio-based plastic packaging can play a complementary role in Europe’s transition away from fossil carbon under the Packaging and Packaging Waste Regulation. The study examines the technological readiness, environmental performance and policy options for bio-based feedstocks in plastic packaging, at a time when the PPWR is reshaping expectations around recyclability, recycled content and circularity.

The report addresses a key gap in the current policy framework. While the PPWR introduces binding recycled-content targets for plastic packaging, the role of bio-based carbon remains less clearly defined. This matters because plastics are still more than 99% fossil-based globally, while bio-based polymers represent only around 1% of the market. According to nova-Institute, this low market share does not reflect a lack of technical maturity.

The study identifies 17 commercially available bio-based polymers and finds no fundamental technical barriers to their use in packaging. This suggests that the main obstacles are not material feasibility, but cost, infrastructure, policy recognition and market scale. For the packaging industry, this distinction is important because it shifts the debate from whether bio-based materials can work to how they should be integrated into regulation and supply chains.

Bio-based carbon and recycled carbon should not be treated as competing solutions; both can support packaging defossilization in different ways.

nova-Institute argues that recycling and bio-based feedstocks perform different but complementary functions. Recycling keeps existing carbon in circulation, reducing the need for virgin fossil resources. Bio-based feedstocks introduce additional renewable carbon into the system. In a climate-neutral packaging sector, both approaches may be needed, alongside carbon dioxide utilisation and improved circular design.

This point is especially relevant because recycling alone may not provide enough non-fossil carbon to meet long-term material demand. Even with higher collection rates and better recycling technologies, losses occur through contamination, degradation, downcycling and product applications that cannot rely entirely on recycled content. Bio-based materials could help close part of that gap, particularly where suitable sustainability criteria are in place.

• Bio-based polymers are already commercially available for several packaging applications.
• Recycled content keeps existing carbon in use and supports circularity.
• Bio-based feedstocks can introduce renewable carbon into the plastics system.
• Binding targets could accelerate investment and market adoption.

The study also highlights greenhouse gas reduction potential. Many bio-based plastics can deliver significant emissions savings compared with fossil-based alternatives, depending on feedstock, production route, energy use and end-of-life treatment. However, these benefits depend on credible sustainability criteria, including responsible land use, traceability and alignment with existing European renewable energy and biomass policies.

Scaling remains the main challenge. Bio-based plastics often face higher production costs, limited infrastructure and less favourable policy support than biofuels. Without clearer policy signals, packaging producers may hesitate to invest in material qualification, supply contracts and processing capacity. The report therefore recommends measures such as binding bio-based content targets, harmonised sustainability criteria and stronger investment in recycling and processing infrastructure.

For packaging producers and brand owners, the policy direction could have major implications. If the EU recognises bio-based content more explicitly within PPWR implementation, companies may gain another route to reduce fossil dependency beyond recycled content alone. This could be especially valuable for applications where recycled plastic supply is limited, performance requirements are demanding or food-contact rules restrict recycled material use.

The report does not suggest replacing recycling with bio-based materials. Instead, it supports a broader renewable carbon strategy. The most resilient packaging system would combine reduction, reuse, recycling, bio-based feedstocks and carbon utilisation, depending on the application. This approach could help avoid overreliance on a single pathway and provide more flexibility for different packaging formats.

The analysis also reinforces the importance of policy certainty. Packaging companies are making long-term decisions on materials, machinery, sourcing and compliance. Clear definitions, harmonised rules and measurable targets would help reduce uncertainty and support investment in bio-based polymers where they deliver verified environmental benefits.

For the European packaging sector, nova-Institute’s study adds scientific weight to the argument that defossilization will require more than recycled content targets. Bio-based plastics remain a small part of the market, but the technology is available and could become more relevant if supported by coherent regulation. Under the PPWR, the next step will be determining how renewable carbon can be recognised without weakening recyclability, circularity or sustainability standards.