As the Packaging and Packaging Waste Regulation (PPWR) moves towards full implementation, recycled content and recycling targets have climbed to the top of the industry’s agenda. But according to Krzysztof Krajewski, Chief Sustainability and Innovation Officer at RDM Group, a rising recycling rate should not be mistaken for genuine circularity. In this op-ed for Paper Industry World, Krajewski argues that the real test lies not in how much material gets recycled, but in what happens to it once it re-enters the system — and what it was made of in the first place.
The Packaging and Packaging Waste Regulation (PPWR) is pushing recycled content and recycling targets to the top of the industry’s agenda. This is a welcome move towards better recycling across the EU, but it also reinforces the assumption that a higher recycling rate automatically means greater circularity. That’s a half-truth.
More recycling might happen once PPWR comes into full implementation, but the real question is what happens to material once it re-enters the system, and what it was made of to begin with.
A design habit that locks recycled content out
Part of the problem is a habit baked into how packaging gets designed. Virgin material is treated as the default for anything premium, and recycled content is slotted in later, once the design is already fixed, usually for whatever application is left over. That ordering is the issue. If recycled content is only considered after the fact, it keeps ending up in lower applications because nobody built a place for it at the start, despite being capable of relevant application.
This has created a false association of recycled as cheaper and virgin as premium. There’s no technical reason cartonboard made with recycled content can’t sit at the same premium tier as virgin board. The constraint lays fully within the design process. Brands without a genuine 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 genuinely required, not reserved by habit for whatever needs to look shiniest on shelf.
The greenwashing risk in “recyclable”
This is where the “recyclable” claim risks greenwashing. A pack can be technically recyclable and still contain no recycled content whatsoever, and plenty do. Slapping a recyclable label on packaging that was never designed with recycled fibre, gives the impression of sustainability while existing outside the original ecosystem. 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.
Beyond the substrate 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 what category it falls into. A pack 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, what will be next application, at what rate, or whether that material is finding its way back into equivalent packaging.
Content thinking, not claims thinking
None of this argues against PPWR’s ambitions. It argues for brands to stop treating recycled content as something reserved for lower tiers, and to stop treating “recyclable” as a finished answer. High-value packaging should include recycled content as well, from the very start, as standard, not as an afterthought, and not as a label used in place of the real thing.