The nova-Institute, a research and consultancy organization specializing in renewable carbon (carbon from non-fossil sources), has published a study commissioned by the European Commission examining the role of bio-based feedstocks in plastic packaging under the Packaging and Packaging Waste Regulation (PPWR). The report, released on 27 April 2026, addresses a gap that the PPWR itself leaves open: while the regulation sets binding recycled content targets for plastic packaging, it does not yet clearly define how bio-based carbon should contribute to the broader goal of moving away from fossil resources. The study provides the scientific groundwork that the Commission may draw on when shaping future sustainability criteria for bio-based plastics.
TABLE OF CONTENTS
The Gap in the PPWR Framework
The PPWR establishes ambitious recycled content requirements as a central mechanism for reducing the fossil carbon footprint of plastic packaging. But recycling, on its own, cannot supply all the non-fossil carbon the sector will need. Recycled material keeps existing carbon in circulation, it does not introduce new renewable carbon into the system. As demand for non-fossil feedstock grows, a framework built on recycling alone leaves a structural shortfall.
This is the gap the nova-Institute report addresses. It argues that bio-based feedstocks (polymers derived from biological sources rather than petroleum) represent a complementary route to defossilization, bringing additional renewable carbon into the material cycle rather than simply recirculating what is already there. The report’s central framing is that recycled and bio-based carbon should be treated as complementary rather than competing approaches, each contributing to the same objective in a different way.
What the Study Found
The report reaches several conclusions relevant to packaging producers and policymakers. Although plastics remain more than 99 % fossil-based globally, with bio-based polymers accounting for only around 1 % of the market, the study finds that these materials are already technologically mature. Seventeen bio-based polymers are commercially available today and the analysis identifies no fundamental technical barriers to their use in packaging applications.
The study also documents the greenhouse gas reduction potential of bio-based polymers relative to their fossil-based equivalents, positioning them as a meaningful contributor to the packaging sector’s climate objectives. At the same time, it acknowledges that despite their technical readiness, bio-based plastics still face barriers to wider adoption, barriers that are largely economic and regulatory rather than technological.
The Policy Recommendations
The report’s practical significance lies in its recommendations for how EU policy could better integrate bio-based feedstocks. Three themes stand out.
First, it calls for harmonised sustainability criteria for bio-based plastics, aligned with the framework already established under the Renewable Energy Directive. Consistency across policy instruments would reduce the fragmentation that currently complicates the treatment of bio-based materials.
Second, it recommends recognising the equivalence and complementarity of bio-based and recycled content within the policy framework, rather than privileging one over the other. As nova-Institute founder Michael Carus put it, a climate-neutral packaging sector will require a balanced mix of bio-based carbon, CO₂ utilisation and recyclingincreasing both the share of bio-based content and the use of recycled materials.
Third, the study points toward the potential value of binding targets to drive the uptake of bio-based content, mirroring the approach the PPWR has taken with recycled content. Whether the Commission adopts such an approach remains to be seen, but the report provides the evidence base for that discussion.
What This Means for the Packaging Industry
For packaging producers, the report is a signal of where EU policy thinking may be heading. The recycled content obligations of the PPWR are now well understood and are driving investment across the sector. Bio-based content, by contrast, has so far occupied an ambiguous position in the regulatory framework Although it is technically viable and environmentally beneficial in many applications, it does not have the binding targets or clear criteria that have accelerated recycled content adoption.
If the Commission moves toward defining sustainability criteria and potentially targets for bio-based feedstocks, producers who have treated bio-based materials as a niche consideration may need to reassess. The report does not create any new obligation, but it strengthens the case for bio-based content becoming a more formal part of the EU’s defossilisation strategy over the coming years.
Conclusion
The nova-Institute study does not change the PPWR, but it contributes to the scientific foundation on which future policy decisions about bio-based packaging will rest. Its central message, that recycling and bio-based feedstocks are complementary tools for reducing fossil carbon in packaging, not alternatives, is likely to shape how the Commission approaches the next phase of packaging sustainability policy. For an industry still absorbing the recycled content requirements of the PPWR, the report is a reminder that the regulatory conversation about non-fossil carbon is far from settled.
