Paper packaging, for some items, has always existed, but as many industries engage in a drive towards sustainability, it’s proliferating.
From replacing cans with cartons, to replacing foil sweet wrappers with paper ones, paper packaging is on the rise.
And the market is growing. According to Grand View Research, it is expected to grow at a CAGR of 4.4% between 2025 and 2030, and in 2024 was valued at $297bn.
But with the introduction of the European Union Deforestation Regulation (EUDR), scheduled to come into force at the end of this year, unrecycled paper could come under more scrutiny. How relevant is this to paper packaging? Could the regulation impact it?
The EUDR and paper
Of the seven commodities covered by the EUDR, paper is not one of them. However, it is included within the category of ‘wood’. According to the WWF, paper and paperboard consist of around 13-15% of the total wood consumed, and uses 33-40% of industrial wood traded globally.
Thus paper comes under the scrutiny of the regulation, and manufacturers of paper that is not wholly recycled will be required to perform due diligence.
“The EUDR will have significant effect on packaging producers, as they will have to comply with new rules – above all, the obligation to compile a due diligence statement for the products they place on the market, and to check the due diligence systems of their suppliers,“ explains a spokesperson for the Confederation of European Paper Industries (CEPI).
Importantly, they explain, it is not the food manufacturer that will be mainly affected by the regulation, but the packaging manufacturer.
“It is important to remember that packaging users (for example, in the food industry) are outside of the scope of the EUDR. This means that they will not have to perform any extra administrative task if they use fibre-based packaging; they will not get checked by the Competent Authorities, for example. The packaging manufacturer, on the other hand, may get checks.”
The impact on the packaging industry
“All paper packaging is required to comply with the new rules, unless it is 100% recycled,” explains Cepi’s spokesperson.
“If there is a mix of virgin and recycled fibres in the mix, the producer has to comply with EUDR obligations only for the share of virgin fibres in the mix.”
According to CEPI, the utilisation rate of total paper and board packaging – essentially the proportion of paper and board packaging that is made from recycled material – is 77.3%. For wrappings and other packaging specifically, it’s only 42.9%.
Thus, manufacturers may not always need to perform due diligence under the EUDR, but in a significant number of cases it will be necessary.
This does not, of course, mean that all non-recycled paper is linked to deforestation. But it does mean that paper packaging manufacturers will have significantly more to worry about when it comes to regulatory compliance.
