European Commission consults the public until 13 January 2027 on the use of bio-based raw materials in plastic packaging

The European Commission has launched a consultation on the use of bio-based raw materials in plastic packaging to assess whether usage targets and sustainability requirements are needed. Businesses, authorities, researchers, environmental organisations and citizens can submit comments until midnight Brussels time on 13 January 2027. The initiative launched on 21 October does not introduce a mandatory quota, nor does it allow producers to replace recycled content with bio-based plastic at this stage.

In brief, the Commission is consulting the public on bio-based raw materials in plastic packaging until midnight Brussels time on 13 January 2027. Possible usage targets, sustainability criteria, costs and compatibility with recycling are being assessed. Producers, recyclers, authorities and citizens can contribute. Replacing recycled content is only a possible legislative option, linked to the unavailability of suitable technologies for food packaging that complies with EU requirements. Bio-based plastic is not automatically biodegradable, compostable or recyclable. The source of the biomass and effects across the entire life cycle are relevant to the assessment. The Commission’s assessment must be completed by 12 February 2028. This is not a compliance deadline for producers, and the consultation does not change current obligations. Responses should be submitted through Have Your Say and may be drafted in any official EU language. Any new rules would require a legislative proposal and its adoption.

The consultation examines the availability of raw materials, material performance, the environmental impact of production and the compatibility of packaging with recycling. The Commission is assessing whether measures to stimulate demand could reduce the use of fossil-based raw materials without compromising circular economy objectives. For packaging producers, the food industry and recyclers in Romania, this is an opportunity to present costs, technological difficulties and data on the materials used.

Bio-based raw materials may come from biomass, organic waste or by-products. Their origin does not guarantee that the resulting plastic is biodegradable, compostable or recyclable in existing facilities. The assessment must take into account the source of the biomass, land use, energy consumption and effects across the entire life cycle, not merely the replacement of a fossil resource.

One of the options under examination concerns the relationship with recycled content targets for packaging. The legislation provides for the possibility of a future proposal allowing bio-based plastic raw materials to be used instead of content recovered from post-consumer plastic waste if suitable recycling technologies are not available for packaging intended to come into contact with food and complying with European safety requirements.

This condition is not an exemption that a producer can invoke now, nor does it establish a general equivalence between bio-based and recycled material. The lack of a producer’s own recycling facility is not, in itself, the criterion laid down by the regulation. A legislative proposal from the Commission and the adoption of new rules would be required; the consultation does not modify existing obligations.

The assessment must be completed by 12 February 2028, under the European regulation on packaging and packaging waste. Article 8 requires European biomass sustainability criteria to be taken into account and provides, if justified by the results, for a legislative proposal on sustainability requirements, usage targets and the possible replacement of recycled content. The date is the deadline for the Commission’s assessment, not a new compliance deadline for manufacturers.

Comments should be submitted through the questionnaire available on the Have Your Say platform. The Commission specifies that responses may be drafted in any official EU language, even though the launch notice initially indicated that the consultation was available in English. Participants may provide evidence on supply, costs, recyclability and the possible effects of the measures on the production chain.

The initiative is part of the European strategy for a competitive and sustainable bioeconomy. At this stage, the Commission is collecting data to determine which interventions are justified. Any targets for bio-based materials will depend on the assessment and the future legislative process, while packaging will continue to have to be properly managed after use.