More importantly it’s necessary to understand that this kind of requirement for the recycled materials is stemming from the plastic side where it's actually necessary to create a kind of a market for the recycled plastics. And there hasn't been, traditionally, enough outlets for recycled plastics.
The same is not true for the fibre market or paper-based materials. There's a huge secondary market for recycled fibre, container board being by far the biggest component of that. But there are other grades as well, like tissue or newsprint or some other industrial grades. So actually, incorporating recycled fibres into materials requiring food safety, in my opinion, is not the best way to proceed. There might be some, let's say, exceptions to this rule, especially in the areas where the food contact regulation is perhaps not so tight. Or that you have a very, very special niche recycled fibre that can be used. But as a mainstream, I don't think that would be the right way to go.
How do you see converters and brands starting to prepare their packaging for PPWR?
Ashley: Good question. Now that PPWR is applicable as of last month, we are really seeing our customers and brands preparing their DOCs, (declarations of conformity), which we, as the label supplier, would provide technical documentation for supporting that process.
And then of course this PPWR Article 5, which focuses on substances of concern, including PFAS, which is a big topic, especially for food contact applications.
We're also seeing many questions around the design for recycling criteria. There is a lot of education that's happening around the fact that these DFR criteria have not yet been established and integrated into the legislation. We will see that, of course, come in later, in 2028 with the delegated acts for Article 6. I would say there’s quite a lot of activities ongoing at the moment. But from my point of view, this DOC is the most critical, and these Article 5 points. So that's what we're seeing, at least in our markets.
What is the difference between fossil and bio-glycols?
Marinela: Chemically and functionally there is no difference. The BioMEG from our Leuna biorefinery is designed as a 1-to-1 drop-in replacement for its fossil-based equivalent. The only difference is the origin of the carbon, the production pathway, the associated certification, and the carbon footprint. Once converted into PET, the material can use the same manufacturing and recycling infrastructure. And this doesn't stand only for PET production but everywhere where glycols are used. We will produce two types of glycols in Leuna and both are stand-in replacements for the fossil versions.
Do you see any interest in compostable solutions?
Janne: To some extent, yes, although the recyclability seems to be kind of a global trend and I guess in many areas outside of the EU, EU regulation is followed up pretty closely for potential imports to this area, and also seen as kind of the highest standard that there currently is. But of course, recycling is not always the only solution or a perfect solution from that perspective. Even if the material as such is recyclable, it doesn't mean anything if it's not recycled. The recycled-at-scale targets for Europe are valid. But this would also be needed for other parts of the world where the recycling infrastructure is not in such good condition. And therefore, littering-related issues, or mismanaged or overflowing landfills, plays a role in packaging design. Here I would say compostable, or at least biodegradable, solutions come into play. Brand owners don't typically want to market on the packaging based on biodegradability, because they don't want to have it as a kind of a licence to litter or anything like that. But I would consider it an insurance against leakage into nature. So, to some extent yes, there is a need for these solutions as well.
Which kind of renewable bio-based content are you using in your new materials/mediums (for example, flexible packaging and PSA)?
Ashley: From the perspective of label materials, of course, one is wood-based biomaterials. And then the other notable form is from used cooking oil. And then both of those, of course, would also have ISCC plus chain of custody certification for the traceability.
Janne: And if I just continue briefly on that, of course, the renewability with the paper-based packaging is already there. So, the big majority of our material is of renewable origin and bio-origin. But of course, we do have an R&D pipeline where we are looking into these bio-based opportunities and solutions with our co-creation partners. You just need to follow our launches and innovation news to see that these products are there. Perhaps not yet as a huge mainstream because they often start small from startups and evolve into scale-ups and ultimately then into more regular businesses. But I would say we are on the way. But in many cases, of course, many of these let's say incumbent coatings tend to be fossil-based to start with.
PFAS free paper coatings. Are there good solutions available?
Janne: Matching the performance of PFAS-based concepts is not always easy, as applying the grease resistance mainly via coating solutions is not exactly the same as having the body of the paper made greaseproof through the use of PFAS chemistry. Finding cost-effective, recyclable solutions with adequate performance is doable, although in some cases modifications to packaging design may be helpful to ease the task.
Do you see a market shift coming for either papers or films as a direct result of regulatory changes such as PPWR?
