European Paper Packaging Alliance says European Environmental Bureau’s report on disposable paper-based food packaging is based on incomplete or inaccurate research, makes false claims about plastics, PFAS, deforestation, industrial water consumption

Sample article from our Packaging Industry

September 14, 2023 (press release) –

Once again, NGOs whose mission seems to be to support the reusable plastics industry at all costs, have issued a report based on demonstrably false claims and assumptions. Such misleading information taints the EU legislative process and undermines truly sustainable and circular solutions to the EU’s plastic waste and climate challenges.


We feel it is important to address just some of the most unsubstantiated claims in EEB’s report upfront. The report authors themselves admit that many of their “facts” are based on incomplete or inaccurate research and data. Some of the assertions in their findings are simply wrong.

1. We find it strange, to say the least, that environmental NGOs are advocating for no plastic and simultaneously support the legislation that adds more plastic waste as this is what reusables will produce. 

Plastic is recognised as one of the most damaging products to the planet’s ecosystems (seas, rivers, and animals).

2. The claim that European paper packaging “drives global deforestation” is false.

European paper packaging is made from renewable wood fibre, which originates from sustainably managed forests. The State of Europe’s Forests, published in 2020 by ForestEurope, confirms that operators plant more trees than are harvested, with the result that European forests grow by 612 million m2 per year. The renewable fibre-based raw materials, which go into our members’ paper packaging, are certified (PEFC/FSC). Furthermore, the European Union Regulation on Deforestation-free Products (EUDR) explicitly restricts the uncontrolled import of products from areas at risk of deforestation. The European paper industry uses wood fibre from tree thinning and leftovers – not the main parts of the tree. Three to five new trees are planted for every tree used. In addition to this, the sustainable forests we plant in Europe sequester every year, in their biomass, around a tenth of the carbon dioxide emissions produced in other sectors. Europe’s forests have grown by 44,000 square kilometres in the past 10 years. That’s the equivalent of 1,500 football pitches. What’s more, these forests absorb 20% of all the European Union’s fossil emissions every year – 806 million tons of CO₂.

3. The claim that paper packaging “rarely includes recycled content” is false.

Single-use paper packaging is fully recyclable, renewable, and sustainable, with its fibre being recycled up to 25 times or more. Currently, more than 75% of Europe’s paper packaging comes from recycled paper and board.

4. The claim that known cancer causing chemicals, or PFAS, are used unsafely throughout paper packaging manufacture is unsubstantiated. 

This area is highly regulated by EU law to ensure public safety and health, and any allegations that packaging may be contaminated in a way that would affect public health or that would make it unsafe are completely unfounded.

5. The claim that paper packaging drives “industrial water consumption” is false.

The Life Cycle Analysis (LCA) by Ramboll in 2020 proves that, due to intensive washing requirements, reusables consume 3.4 times more freshwater than single-use paper packaging in Quick-Service-Restaurants (QSR) settings. It is reusables that will add stress to Europe’s already beleaguered water supply – especially in areas that are already most under pressure.

6. The claim that paper packaging is the “largest source of packaging waste in the EU” is false.

This claim completely ignores recycling rates and the environmental impact of different waste categories. In 2022, the European Commission found that paper packaging had an 81.5% recycling rate, compared to a mere 40% for plastic packaging. Food service paper packaging is less than 1% of the amount of paper packaging waste generated. The recovery paper industry has been able to grow in the last 30 years, covering all the needs without putting at risk the capacity to recycle, with the result that our industry has already achieved the EU Commission recycling target rate for 2025 (80%).


The primary function of food packaging is to assure food safety and avoid cross-contamination. Our products are made to protect consumers, and that function cannot be compromised. Paper-based food packaging is also essential in preventing food waste and making the food chain more sustainable.

As stated, we believe the authors of this report use these false and misleading claims to arrive at the conclusion that all single-use packaging should be immediately banned or phased out in restaurants and takeaway settings. In contrast, unlike the NGOs, we are not calling for a ban on any single type of packaging, but in the QSR sector, scientific data clearly shows that renewable, recyclable paper-based packaging is best for the environment, economy, and consumers.

We believe theirs is an extreme position that is based on ideology rather than being backed up by science. It would instead lead to a tsunami of plastic waste flooding the European market, while massively driving up costs for small businesses and increasing water consumption, energy consumption and carbon emissions.

We call on all policymakers to stand for a PPWR based on common sense and science. There is a place for reusable packaging and single-use but each application should be studied thoroughly rather than a blanket ban being introduced. There should be no place in the EU for policy based on bad science and pure ideology.

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Dan Rivard
Dan Rivard
- VP Market Development -

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