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As the EU Packaging and Packaging Waste Regulation (PPWR) pushes recycled content and recycling higher up the food packaging agenda, the industry is being forced to look beyond simply whether a pack can be recycled. The more important question is whether recycled fibre is being designed back into the packaging loop in the first place. For food brands, that means challenging the long-standing assumption that virgin fibre belongs in premium packaging while recycled content is reserved for less demanding applications. As Krzysztof Krajewski, chief sustainability and innovation officer at RDM Group, argues, true circularity starts at the design stage, with recycled fibre treated not as an afterthought, but as a credible, high-value material for food packaging.

The Packaging and Packaging Waste Regulation (PPWR) is pushing recycled content and recycling targets to the top of the food packaging industry's agenda. That's welcome, but it feeds an assumption worth challenging: that a higher recycling rate automatically means greater circularity. It doesn't, not on its own.

More recycling might happen once PPWR reaches full implementation, but the real question for cartonboard is what happens to material once it re-enters the system, and what it was made of to begin with.

Recycled vs virgin packaging

Part of the problem is a habit baked into how food packaging gets designed. Virgin fibre is treated as the default for anything premium, like a shiny box of biscuits, but rarely containing recycled content in it. That ordering is the issue. If recycled content is reserved as an option for secondary applications or other 'less demanding' packaging industries, it quickly drops down in the tier of possible applications. Not because it can't perform, but because nobody built a place for it at the start.

This has created a false association: recycled as cheaper, virgin as premium. There's no technical reason cartonboard made with recycled content can't sit at the same premium tier as virgin board on a shelf-edge food packaging.

Food contact safety requirements are the one real constraint, and they apply to a narrower slice of the category than brands assume. Outside of that, the constraint lies entirely in the design process. Brands without a safety reason to insist on virgin fibre should be specifying recycled content from the first sketch of a pack, not leaving it for another brand down the line to deal with. Virgin material should be kept for cases where it's required, not reserved by habit for whatever needs to look shiniest on shelf.

Recycled fibre is already used safely in food packaging across many categories: cereals, bakery products, confectionery, fruit and vegetables, frozen foods and other dry foods. Recycled fibres may carry trace contaminants from the recovery stream, but this is controlled through strict sourcing of raw materials, de-inking and cleaning processes, compliance testing, and functional barriers where needed. Fatty, moist or long shelf-life foods need extra protection, which barrier layers or inner liners provide by preventing substance migration. This risk-based approach shows that recycled content and food safety aren't at odds; packaging can deliver both.

The 'recyclable' claim has its own problem with risking greenwashing, and food cartonboard is where it shows up most. A pack can be technically recyclable and contain no recycled content whatsoever, and plenty on supermarket shelves do. Putting a recyclable label on a carton that was never designed with recycled fibre gives the impression of sustainability while sitting outside the loop it claims to support. Recyclable and recycled are different things, and only one of them proves the loop is closing. If you're not putting recycled content in, claiming the recyclable badge is taking credit for a job you haven't done.

The packaging debate

Much of the packaging debate fixates on substrate: paper versus plastic, cartonboard versus film. This misses the point. What matters is what happens to the material after use, and what went into it in the first place, not just which category it falls into. A carton that's recyclable in theory but built entirely from virgin fibre hasn't done anything for circularity yet. It's simply deferred the question to someone else, later, maybe.

PPWR sets thresholds for recycled content, but the fibre space isn't regulated on this the way plastics are, and a threshold on paper doesn't tell you who is actually recycling food cartons, at what rate, or whether that material is finding its way back into equivalent food-grade packaging.

None of this argues against PPWR's ambitions. It argues for food brands to stop treating recycled content as something reserved for lower tiers, and to stop treating 'recyclable' as a finished answer. High-value cartonboard packaging should include recycled content from the start, as standard, not as an afterthought, and not as a label used in place of the real thing.