What are the PPWR Article 8 requirements for biobased feedstock?

Article 8 of the Packaging and Packaging Waste Regulation establishes a framework for evaluating and potentially mandating the use of biobased feedstock in plastic packaging. By 12 February 2028, the European Commission must review the technology and environmental performance of biobased plastic packaging, potentially leading to new sustainability targets.

For many online sellers and packaging manufacturers, shifting away from petroleum-based plastics is a core sustainability goal. Biobased plastics offer a compelling alternative, as they are derived from renewable biological sources such as agricultural by-products, algae, or organic waste. However, swapping fossil fuels for plant-based materials does not automatically mean a package is better for the environment. Regulators need to ensure that growing crops for packaging does not compete with food supplies or drive deforestation.

This is where Article 8 of the PPWR comes onto your radar. Instead of setting immediate, hard targets for biobased plastics from day one, the regulation establishes a timeline for the European Commission to study the technology, assess its true environmental impact, and decide how it fits into the broader circular economy. For merchants and brands planning their packaging strategies for the next decade, understanding this article is vital because it lays the groundwork for future mandates and exceptions, particularly for food-contact materials that struggle to meet standard recycled content rules.

What PPWR Article 8 actually means

Article 8 tasks the European Commission with reviewing the technological development and environmental performance of biobased plastic packaging by 12 February 2028, potentially leading to future sustainability requirements and usage targets (Packaging and Packaging Waste Regulation (EU) 2025/40).

The article formally addresses plastics made from biological resources, which the PPWR defines as biomass feedstock, organic waste, or by-products, regardless of whether the resulting plastic is biodegradable or non-biodegradable. The core mechanism of Article 8 is a mandated review. By 12 February 2028, the Commission must review the current state of biobased plastic packaging, taking into account specific sustainability criteria laid down in Directive (EU) 2018/2001.

Depending on the findings of this review, the Commission has the power to present a legislative proposal to introduce new obligations for the market. These potential new rules could lay down sustainability requirements for biobased feedstock and set binding targets to increase its use in plastic packaging. For the food and beverage sector, the review could also introduce the possibility of using biobased plastics to meet the mandatory recycled content targets outlined in Article 7. This substitution would only be permitted if suitable recycling technologies for food-contact packaging, which comply with Regulation (EU) 2022/1616, are not available. Finally, the proposal could also amend the legal definition of biobased plastic if the evidence points to a need for greater legislative clarity.

Does this apply to me?

Currently, Article 8 does not impose immediate compliance obligations on merchants selling packaged goods into the European Union. Instead, it places a direct obligation on the European Commission to conduct a review and propose future legislation by the 2028 deadline. However, any business relying heavily on plastic packaging, especially those in the food and beverage industry, needs to monitor this space closely to inform their long-term procurement decisions.

If you manufacture or import plastic packaging into the EU, the outcomes of the 2028 review will dictate whether your biobased packaging can count towards your overall sustainability targets. This is particularly relevant if you use contact-sensitive packaging where incorporating post-consumer recycled plastic poses food safety risks, or where suitable recycling technologies are legally or practically unavailable.

Furthermore, while you are not yet forced to use biobased plastics or label them, if you choose to make marketing claims about your biobased content, you will eventually have to adhere to strict rules. The PPWR notes that labelling biobased plastic content is not mandatory because more scientific evidence is required to prove its alignment with circular economy principles. However, if you do mark your packaging with a label indicating biobased content, it must comply with specific harmonised specifications that the Commission will establish via implementing acts.

When must the European Commission review biobased plastic packaging under Article 8?

The dates and targets for biobased feedstock are set by Article 8 and its related provisions, on a legislative timeline that runs well past the regulation's own entry into force.

Common misconceptions about biobased feedstock

“Biobased plastics automatically count towards recycled content targets”

This is not true right now. Currently, recycled content targets under Article 7 strictly demand post-consumer plastic waste. Article 8 merely states the Commission will consider allowing biobased plastics to count towards these targets in the future, specifically for food-contact packaging where recycling technologies are lacking.

“Biobased means biodegradable”

This is a frequent point of confusion in sustainable packaging. The PPWR explicitly defines biobased plastics as those made from biological resources irrespective of whether the plastics are biodegradable or non-biodegradable. A biobased plastic can be structurally identical to a fossil-based plastic (like bio-PET) and designed for long-term durability and standard material recycling.

“You must label your biobased packaging immediately”

There is no mandatory requirement in the PPWR to label biobased plastic content, because more scientific evidence is needed to ensure its use aligns with circular economy principles over its entire life-cycle. However, if you voluntarily choose to apply a label to your product, you must follow the EU's forthcoming harmonised specifications.

“Article 8 bans fossil-based plastics immediately”

Article 8 does not ban conventional plastics. It creates a framework for assessing biobased alternatives and potentially setting future targets to increase their use. The PPWR tackles fossil-based plastics primarily through mandatory recycled content minimums rather than outright bans on the petroleum feedstock itself.

4 examples of how biobased feedstock impacts packaging strategies

Food-contact plastic manufacturers:

A company making plastic film for fresh meat struggles to find food-safe recycled plastic. They will watch the 2028 review closely, as it might eventually allow them to use biobased plastics to satisfy their mandatory recycled content targets if safe recycling technology remains legally unavailable.

Voluntary environmental marketing:

A cosmetics brand wants to advertise that its shampoo bottles are made from sugar cane. Under the PPWR, while this label is voluntary, the brand will have to wait for and comply with the EU's specific implementing acts on biobased labelling to avoid misleading or confusing consumers across the internal market.

Agricultural by-product sourcing:

A packaging supplier begins sourcing organic waste and biomass to produce bio-PE for distribution boxes. They must ensure their sourcing aligns with the sustainability criteria from Directive (EU) 2018/2001, as the Commission will use these exact criteria when laying down future sustainability requirements for biobased feedstock.

Non-biodegradable biobased plastics:

A beverage company switches to bio-PET for its water bottles. Even though the feedstock is biological, the bottle does not degrade in nature. Because biobased plastics can be non-biodegradable, the company still has to ensure the bottle is fully recyclable by 2030, just like a conventional fossil-based PET bottle.

Terms related to PPWR Article 8

Frequently asked questions

What is the definition of biobased plastic under the PPWR?

The PPWR defines biobased plastics as plastics made from biological resources, such as biomass feedstock, organic waste, or by-products. This definition applies irrespective of whether the resulting plastic is biodegradable or non-biodegradable.

Will biobased plastics help me meet my recycled content targets?

Not immediately. However, the European Commission will review this by 12 February 2028. Following the review, they may introduce the possibility to achieve recycled content targets using biobased plastic feedstock, specifically if suitable recycling technologies for food-contact packaging are not available.

Do I have to use a specific label if my packaging is biobased?

Labelling biobased plastic content is completely voluntary under the PPWR. If you do decide to label your packaging to highlight its biobased content, the label must comply with detailed specifications that will be laid down in future EU implementing acts.

Does biobased plastic mean the packaging is compostable?

No. While some biobased plastics are compostable, the PPWR explicitly states that the definition of biobased plastic includes materials that are non-biodegradable. If a package is designed to be compostable, it must meet separate, specific criteria outlined in Article 9.

When will the EU set firm targets for biobased packaging?

The European Commission is required to review the technological development of biobased plastic packaging by 12 February 2028. Based on that review, the Commission may present a legislative proposal to lay down firm targets to increase the use of biobased feedstock in plastic packaging.

Sources:

• Packaging and Packaging Waste Regulation (EU) 2025/40