Knowledge

Paper or plastic? A decision framework for the EU market

Paper versus plastic is rarely a values question — it is a specification question. The answer usually comes out of four variables: what the product needs, what the shelf needs, what the market's collection streams can handle, and what the EU rules will require in 2030.

Start with what the product needs

• Moisture and oxygen sensitivity. Dry biscuits survive in a paper-based pack; ground coffee and crisps usually need a barrier that paper alone does not provide.
• Fat and liquid. Fatty and liquid products need a grease or liquid barrier — a coated board, a liner, or a plastic structure.
• Temperature. Frozen, chilled and hot-filled products narrow the field quickly.
• Weight and logistics. Paper is heavier per unit of protection; plastic is lighter but more sensitive to puncture.

Then what the market can actually recycle

Recyclability is not a property of the material name; it is a property of the material in a given collection stream. A mono-material PE pouch and a PET/PE laminate are both "plastic packaging", but they behave very differently: the first sorts into a film stream in several EU markets, the second generally does not. The same is true of paper: a plain carton repulps, a heavily laminated or foil-stamped one may not.

Under PPWR (Regulation (EU) 2025/40), recyclability becomes a market-access condition graded A (≥95 %), B (≥80 %) or C (≥70 %); packaging below grade C cannot be placed on the EU market from 1 January 2030. That date is the reason this decision belongs at the specification stage, not the packaging-development stage.

Then the compliance route

• Food contact: plastics are covered by the EU 10/2011 positive list; paper and board are covered by national rules and mill declarations. Both need documentation, not assurances.
• The Declaration of Conformity obligation under PPWR Article 15 applies from 12 August 2026 — before the goods are placed on the market.
• Germany adds the LUCID register and dual-system participation, which need material type and weight per unit from the supplier.

A workable default

For a brand starting a range, the pragmatic sequence is: paper-based where the product is dry and the pack does not need a high barrier; mono-material plastic where moisture, oxygen or strength genuinely require a plastic barrier; and a documented multilayer with a stated limitation only where nothing else meets the shelf-life requirement. Documenting the limitation is not a failure — claiming recyclability the structure does not have is.

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