Paper-based packaging vs plastic under PPWR
Paper-based packaging is packaging whose predominant material is paper or cardboard. It includes flexible formats: films, sheets, pouches, lidding and wrappers.
Switching a flexible pack from polymer to fibre does not take it out of the recyclability rules of Regulation (EU) 2025/40. It moves it into a different assessment category, graded against the same A, B and C thresholds.
One threshold decides whether the unit is treated as paper or as composite packaging: 5 % of its total mass. A material that is an insignificant part of the unit, and in any event no more than 5 % of that mass, does not make the pack composite. A functional barrier can cross that line, and on a lightweight paper web it often does.
This page sets out what changes in law and on the recycling line when a flexible structure moves from plastic to paper. It uses the regulation text and published measurement data rather than material preference.
The 5 % threshold that decides whether a paper pack is composite
Article 3(24) defines composite packaging as a unit made of two or more different materials. They form part of the weight of the main packaging material, cannot be separated manually, and therefore form a single integral unit.
The definition carries one carve-out: a material that constitutes an insignificant part of the unit, and in any event no more than 5 % of its total mass. Labels, varnishes, paints, inks, adhesives and lacquers are excluded from the calculation.
Whether a functional barrier fits inside that carve-out is a calculation, not an assumption. It depends on coat weight, coating chemistry, the grammage of the paper and the mass of the finished unit.
Published coating work puts the coat weight needed for a usable barrier at 10 g/m² or more. On a low-grammage flexible web, a layer of that order can already represent well above 5 % of unit mass. It has to be calculated for the actual structure.
Varnishes are excluded from the calculation outright. A sealant or barrier layer is not. Once it passes 5 % of unit mass, the pack is composite packaging. The engineering decision and the legal classification are the same decision.
The same threshold, from the other direction
Article 7(5)(b) exempts from the recycled content targets any plastic part representing less than 5 % of the total weight of the unit. Once a plastic part reaches that share, the exemption no longer applies. Which target applies then depends on the packaging category.
- Contact-sensitive packaging with PET as the major component: 30 % by 2030, 50 % by 2040
- Contact-sensitive packaging made from plastics other than PET: 10 % and 25 %
- Single-use plastic beverage bottles: 30 % and 65 %
- Other plastic packaging: 35 % and 65 %
Single-use beverage bottles are excluded from the first two categories. The figures are calculated as an average per manufacturing plant and year, and the further exemptions of Article 7(4) still apply.
The first deadline is 1 January 2030, or three years after the implementing act on the calculation methodology enters into force, whichever is later.
How PPWR grades paper-based packaging
Annex II, Table 1 splits fibre into two categories.
Article 6(4)(a) requires design-for-recycling criteria and grades to be developed on the basis of the predominant material. A paper-based laminate is therefore assessed against the fibre recycling stream, not the polymer one.
It is still assessed, and against the numerical thresholds in Annex II, Table 3. Grade A starts at 95 %, grade B at 80 %, grade C at 70 %. Below 70 % the unit is technically non-recyclable and its placing on the market is restricted. The criteria behind the score are material-specific and set per category.
The dates that bind
A recycled-at-scale assessment is added from 1 January 2035, or five years after the relevant implementing acts, whichever is later. Article 6(10) allows a time-limited derogation for innovative packaging. Article 6(11) removes certain medical and pharmaceutical packaging from these requirements altogether.
Until that methodology is adopted, no supplier can substantiate an official PPWR recyclability grade, for a paper-based structure or a plastic one. What can be documented today is performance against the current industry test methods.
The barrier gap, in published numbers
Uncoated kraft paper is not a barrier material. Three published results show how wide the range becomes once a coating is added.
Between the first and the last, the oxygen barrier spans six orders of magnitude. The word “paper” on a specification says nothing about barrier performance. The coating chemistry and the coat weight say everything.
The three results come from different studies, on different substrates. Oxygen and water vapour transmission rates are comparable only where temperature, relative humidity and test method are disclosed. Read them as a range, not as a ranking.
The polyvinyl alcohol structure also measured 99.7 % repulpability, so high barrier and clean recovery are not mutually exclusive in the laboratory. The constraint appears at the next step.
Work published in the Journal of Korea TAPPI found that barrier properties, wet strength and disintegration behave as mutually incompatible targets. The treatments that raise barrier and wet strength are the ones that degrade repulping.
Paper-based structures are engineered along that trade-off. Polymer structures are engineered along the barrier-versus-recyclability trade-off covered on the metallised film and EVOH page.
What the recycling mill actually measures
A widely used industry reference for fibre-based packaging is the Cepi Recyclability Test Method, updated to version 3 in 2025. It is read together with the 4evergreen Recyclability Evaluation Protocol, which converts the laboratory results into a score.
These are engineering references, not the PPWR grading methodology. They assess how a structure behaves in one defined mill scenario. They do not assign a universal recyclability label.
For a conventional recycling mill the protocol scores four things.
- Total screening yield. At 95 % or above it earns the top score. Between 85 % and 80 % the score collapses toward zero. At 69 % or below it is set to minus 100 points.
- Sheet adhesion. Not scored on a curve. At level 3 the sample is a knockout, and the packaging is not recyclable in that mill type, whatever the fibre yield was.
- Dissolved and colloidal substances. Scored only downward, from zero to minus 200 points.
- Visual impurities. Four levels, from no penalty to minus 30 points.
Sheet adhesion is the only parameter that can end the assessment on its own. A structure can show good fibre recovery and still fail, if tackiness stops the recovered sheet from being handled. Screening yield, dissolved substances and visual impurities can be decisive too.
A 2024 survey of 58 German paper-industry experts, published in Sustainability, put numbers on the same problem. Seventy per cent treat plastic coatings, wet-strength papers, adhesives and wax dispersions as a problem in the recovered-paper stream. Roughly 90 % expect challenges with fibre-based composites in the existing system.
Repulping trials on some dispersion-coated boards have produced reject fractions of up to 50 %.
There is also a downstream effect that is easy to miss. A 2025 study in Coatings tracked an 8 g/m² dispersion coating through a recycling line. It recovered more than 75,000 secondary microplastic particles, 72 % of them below 100 µm, with the finer fraction concentrating in the wastewater.
A polymer coating on paper does not disappear because the substrate is fibre.
Paper-based packaging is not automatically PFAS-free
Article 5(5) sets the limits for food-contact packaging by substance, not by material. They apply to a paper wrapper exactly as they apply to a polymer film.
- 25 ppb for any individual PFAS measured by targeted analysis
- 250 ppb for the sum
- 50 ppm including polymeric PFAS
- Above 50 mg/kg of total fluorine, the manufacturer, importer or downstream user must provide proof on request of how much of that fluorine is PFAS
Grease and water resistance on fibre is historically where PFAS lived. A 2026 risk-matrix study in Foods was built specifically to support Article 5 screening. It ranks fibre-based materials with grease- or water-resistant treatments above glass, untreated paper and PET for PFAS relevance.
Measurement work supports the ranking. A US survey found detectable fluorine in 46 % of food-contact papers and 20 % of paperboard samples. A later study found at least one detectable PFAS in 84 % of 88 globally sourced packaging samples.
In one Canadian study the highest total fluorine of the whole sample set was measured in moulded fibre bowls marketed as compostable. The authors describe it as a regrettable substitution. A fibre substrate is not evidence of compliance; a test report is.
There are two routes away from PFAS. One is film lamination: a 2021 review in Comprehensive Reviews in Food Science and Food Safety notes that polyethylene, EVOH and PET laminates are neither compostable nor recyclable. The other is dispersion and biopolymer coatings, where repulpability has to be demonstrated for the finished structure rather than assumed.
Removing a chemical compliance problem does not remove the end-of-life question. It relocates it.
The limit values and the documentation route are set out on the PFAS in food packaging page.
What the life cycle evidence supports
The published comparisons do not converge on one winner. The direction of the result depends on which impact categories are counted.
- Coated paper ahead. A 2025 cradle-to-grave assessment in Waste Management compared 14 multilayer plastic films against coated paper-based packaging. The paper came out better on energy demand by 25 % to 34 %, on greenhouse gases by 34 % to 62 %, and on fossil resource scarcity by 81 % to 83 %.
- Paper ahead on most categories. A 2024 study of chocolate bar packaging found paper-based preferred in 10 to 16 of 18 impact categories, depending on the scenario.
- Advantage limited by mass. A 2024 pasta packaging assessment found paper lowered global warming potential and fossil depletion but raised eutrophication and ozone depletion. Its authors called the advantage very limited, because more paper mass is needed for the same function.
- Packaging is the small term. An analysis of 28 food LCA studies found plastic packaging accounts for less than 10 % of total life-cycle emissions for 23 of 30 foods examined.
The end-of-life assumptions matter to the first result. The plastic films were modelled on US landfill and incineration averages, the paper on recycling.
Where packaging affects the food itself, protection dominates the comparison. A systematic review of packaging and food waste concluded that performance in preventing spoilage is the critical variable, not the substrate.
The legislator states its own position in recital 6 of the regulation. Plastic is the most carbon-intensive packaging material. In fossil fuel terms, recycling plastic waste is approximately five times better than incineration with energy recovery. That is an argument about waste management, not about substitution.
Where fibre has a clear systems advantage
Article 52(1)(d) sets the Member State recycling targets for 31 December 2030 at 85 % for paper and cardboard and 55 % for plastic. Article 52(2) lets a Member State postpone those targets by up to five years under conditions.
Eurostat put the actual EU plastic packaging recycling rate at 42.1 % for 2023. The fibre collection and recycling system is older, denser and closer to its target.
That is a systems argument, and it is a real one. It applies to category 2 packaging. It does not transfer automatically to category 3. A laminate that fails sheet adhesion in the Cepi test does not reach the mature stream simply because its predominant material is paper.
Environmental claims on paper-based packaging
A second legal regime applies to what is printed on the pack. Directive (EU) 2024/825 amends the blacklist in Directive 2005/29/EC, and Member States apply the national measures from 27 September 2026.
Point 4a covers generic environmental claims that cannot be substantiated. Point 4b covers a claim about the entire product when it concerns only one aspect of it.
Both are directly relevant here. “Plastic-free” on a polymer-coated paper pack is a claim about the whole unit resting on the visible substrate. “Recyclable” on a structure that has not been tested against the fibre stream is a claim without a substantiation file.
The rules governing what may be stated, and the documentation that supports it, are on the PPWR regulation page.
Choosing between paper-based packaging and plastic
Six questions decide the case for a specific product, in this order:
- What oxygen and water vapour transmission rate does the shelf life actually require, measured rather than assumed?
- What coat weight reaches that barrier, and what share of unit mass does it represent?
- Does the structure clear sheet adhesion and total screening yield in a Cepi-method test?
- Does the plastic part cross 5 % of total weight, and therefore carry a recycled-content obligation?
- Is the product contact-sensitive, and does the grease or moisture treatment have a fluorine test report behind it?
- Does the target market collect and recycle that category, or only the uncoated one?
Where the barrier requirement is low, single-ply fibre answers it, with a mature recovery stream behind it.
Where the barrier requirement is high, the honest comparison is between a coated fibre structure and a mono-material polymer structure designed for recycling, judged on the same test data. That comparison is set out on the design for recycling page.
Frequently asked questions
Is paper-based packaging exempt from the PPWR recyclability grades?
No. Annex II, Table 1 lists paper and cardboard as category 2 and paper-majority composites as category 3. Both are graded A, B or C against the thresholds in Table 3, on the basis of the predominant material.
Does the PPWR recycled content target apply to paper-based packaging?
It applies to the plastic part of it. Article 7 covers any plastic part of packaging, and Article 7(5)(b) exempts a plastic part representing less than 5 % of the total weight of the unit. Further exemptions are listed in Article 7(4). A barrier or sealant layer above that share is in scope.
Is paper-based packaging automatically PFAS-free?
No. Article 5(5) sets limits by substance, not by material. Published surveys have found detectable fluorine in a large share of grease-resistant fibre packaging, including products marketed as compostable. Compliance is demonstrated by a test report.
Does paper have a lower carbon footprint than plastic film?
Sometimes. Published assessments show paper ahead on greenhouse gases and fossil resource use in several cases, and behind on eutrophication and ozone depletion. The mass needed for equal function drives the result. The end-of-life assumptions change the answer.
When do these rules start to apply?
The regulation applies from 12 August 2026. The delegated acts defining the recyclability criteria are due by 1 January 2028. Grade C becomes the minimum from 1 January 2030, or 24 months after those acts, whichever is later. Only grades A and B may be placed on the market from 1 January 2038.
Sources
Regulation (EU) 2025/40, Articles 3, 5, 6, 7 and 52 and Annex II. Directive (EU) 2024/825. Cepi Recyclability Test Method version 3, 2025, with the 4evergreen Fibre-based Packaging Recyclability Evaluation Protocol. Eurostat packaging waste statistics, 2023 reference year. Barrier, repulpability, PFAS and life cycle figures are drawn from peer-reviewed studies published between 2017 and 2026 in Waste Management, ACS Applied Materials & Interfaces, Food Packaging and Shelf Life, Coatings, Foods, Sustainability, Environmental Science & Technology Letters, Chemosphere, Sustainable Production and Consumption, Resources, Conservation and Recycling and the Journal of Korea TAPPI. Each figure is attributed to its study where it appears in the text.
Related resources
If your packaging is built on VLM Poliplast structures, the documentation behind it comes with the supply: technical data sheets and material declarations, per structure. Article 16 PPWR requires suppliers to provide the compliance information a manufacturer needs to demonstrate conformity, and that is what arrives, not a consultancy service.
Recyclability assessments on the current industry reference frameworks are supplied alongside it, as engineering data. Official PPWR grades become documentable once the delegated acts are published.