Bio-based plastic in packaging: the Commission opens the consultation that may bring binding targets

In shortOn 21 October 2026, the European Commission opened the public consultation on bio-based plastic in packaging - the preparatory step of the review required by Art. 8 of the PPWR, to be completed by 12 February 2028. On the table: possible binding bio-based content targets, sustainability criteria for the feedstock and the possibility for bio-based plastic to count in place of recycled content where no suitable recycling technologies exist for food contact. Responses can be submitted until 13 January 2027.

What the Commission launched on 21 October

The Packaging and Packaging Waste Regulation (PPWR) applies from 12 August 2026, but for bio-based plastic - produced from plant-based feedstock instead of petroleum - it sets no concrete requirement for now. Art. 8, however, obliges the Commission to assess, by 12 February 2028, the state of the technology and the environmental performance of these materials, and to decide whether to propose new requirements.

The consultation now open on the “Have your say” portal gathers evidence precisely for that decision: the availability and environmental impact of biological feedstock, the sustainability of cultivation, suitable recycling technologies and the effects of the different regulatory options. The questionnaire is for now in English only; the deadline for responses is 13 January 2027.

Legal basis: Regulation (EU) 2025/40 on packaging and packaging waste, as subsequently amended and supplemented (Art. 8 - bio-based plastic packaging; Art. 7 - recycled content); Directive (EU) 2018/2001 on the promotion of the use of energy from renewable sources, as subsequently amended and supplemented (Art. 29 - sustainability criteria for biomass); Regulation (EU) 2022/1616 on recycled plastic materials and articles intended to come into contact with foods.

Why it matters for companies in Romania

The first reason: the recycled content targets. From 2030, plastic packaging will have to contain minimum percentages of recycled material, and for food-contact packaging the problem is real - recycling technologies authorised under Regulation (EU) 2022/1616 are missing for many materials. One of the options examined in the review is for bio-based content to be able to replace recycled content in those cases. For food and drink producers, this can fundamentally change the packaging strategy for 2030.

The second reason: whoever already uses bioplastics - compostable bags, PLA, bio-PE - or considers them when redesigning packaging now has the official window to flag the practical problems: definitions, calculation method, feedstock availability, prices.

Key point: for now there is no new obligation. The decisions taken on the basis of this consultation will, however, matter directly for the 2030 targets: possible bio-based content targets, sustainability criteria for the feedstock and the equivalence of bio-based with recycled content for food-contact packaging.

What to do now

Take stock of your plastic packaging portfolio: what share bio-based materials have, which packaging is in contact with food and where you stand against the 2030 recycled content targets. If the subject affects you, respond to the consultation by 13 January 2027 - directly or through the industry associations you belong to. Be careful, too, with “bio-based” or “compostable” claims on packaging and in marketing materials: the definitions and possible sustainability requirements are only now being set, and the EU rules on green claims are tightening in parallel.

Circulad'OR tracks for its clients the acts prepared under the PPWR and can help you assess what bio-based or recycled content targets would mean for your portfolio - and packaging data structured in Yvora, our PPWR compliance platform, turns that analysis into a matter of hours, not weeks. If you want to submit a position in the consultation, we prepare it together.