At first glance, Europe’s new packaging rules appear to create an obvious opportunity for paper.

From January 1, 2030, the EU Packaging and Packaging Waste Regulation will restrict single-use plastic packaging for pre-packed, unprocessed fresh fruit and vegetables weighing less than 1.5 kg.

Bags.

Nets.

Trays.

Containers.

For companies supplying fibre-based packaging, that sounds like a large market waiting to convert.

The reality is considerably more complicated.

The regulation allows Member States to create exemptions where packaging is needed to prevent water or turgidity loss, microbiological hazards, physical damage or oxidation. It also recognizes situations where packaging is necessary to keep organic and non-organic produce separate.

And guidance issued by the European Commission in June 2026 adds another important qualification: a paper-based package containing 5% or more plastic by mass as an integral part of the structure can still be treated as single-use plastic packaging for the relevant PPWR restrictions.

That changes the question facing fresh-produce packers.

It is no longer simply:

What can replace the plastic bag?

It is:

What packaging structure can meet the regulation while surviving moisture, transport, automated packing and the biological behaviour of the product inside?

Polish flexible-packaging producer Silbo provides a useful example of how suppliers are approaching that problem.

Its Mr Paper portfolio includes paper packaging combined with linen or viscose mesh, cellulose windows and other structures designed for automated horizontal and vertical packing systems.

The company’s Reelbag goes a step further: Silbo says it can replace the plastic rollstock bags traditionally used on automated bagging equipment with a structure made from paper and organic linen mesh without plastic.

That is exactly the type of technology PPWR could accelerate.

But it also illustrates why fresh-produce packaging’s next transition is going to be an engineering problem rather than a simple materials substitution.

PPWR does not actually say fresh produce must move to paper

This distinction deserves to be clear.

Annex V of PPWR restricts specified single-use plastic packaging formats for less than 1.5 kg of pre-packed unprocessed fresh fruit and vegetables from January 1, 2030.

It does not prescribe paper as the replacement.

That leaves suppliers considerable freedom.

Depending on the product and application, the future pack might use:

paper,

cellulose,

a low-plastic paper composite,

a reusable format,

or another architecture capable of meeting the legal definition while preserving the product.

The exemptions are equally important.

Fresh produce is biologically active.

Potatoes do not behave like berries.

Onions do not behave like mushrooms.

Apples do not behave like leafy vegetables.

Different products lose water at different rates, bruise differently, respire differently and respond differently to humidity.

That explains why PPWR explicitly allows Member States to consider water loss, turgidity loss, microbiological risk, physical shocks and oxidation when determining exemptions.

The regulation is therefore not saying:

plastic packaging has no useful function.

It is effectively saying:

where single-use plastic remains necessary, that necessity increasingly needs to be defensible.

That is a much more demanding packaging-development environment.

The 5% plastic threshold creates a trap for superficial paper conversion

The Commission’s 2026 guidance is particularly relevant for fibre-packaging developers.

A package does not necessarily escape PPWR’s Annex V plastic restrictions simply because paper is the dominant visible material.

Under the Commission’s interpretation, composite packaging with 5% or more plastic by total packaging mass can still fall within the relevant single-use-plastic restrictions.

Paper packaging containing no more than 5% plastic is not covered by those particular Annex V bans on that basis.

That could become a significant design constraint.

A supplier might develop what appears to be a paper bag but add:

a plastic window,

a polymer mesh,

a relatively heavy sealant layer,

or another integral plastic component.

If that pushes the package beyond the relevant threshold, simply marketing it as “paper-based” does not solve the regulatory problem.

This makes material accounting increasingly important.

Packaging developers will need to know not just the dominant substrate but the weight contribution of each component.

For paper suppliers, that could reward structures capable of delivering functionality with very small quantities of coating, adhesive or other auxiliary material.

It could also increase interest in non-plastic components such as cellulose or natural-fibre meshes where they work technically and economically.

Silbo’s Reelbag shows why machinery compatibility matters

Silbo introduced its Reelbag concept in 2024 for automated Rollstock Bagger systems.

These machines have traditionally formed packages from plastic bags supplied on a roll.

Silbo’s alternative combines FSC-certified paper with organic linen mesh windows designed to provide visibility and ventilation. The company says water-based inks and adhesive are used, with adhesive applied only where sealing is required.

The interesting feature is not simply that the package contains paper.

It is that Silbo designed it around existing automated packaging equipment.

That matters commercially.

Fresh-produce companies have already invested in:

weighers,

baggers,

conveyors,

inspection systems,

labelers,

and entire packing halls.

A sustainable package that requires replacing the production line creates a much larger capital barrier than a package that can be adapted to existing equipment.

Silbo says its broader packaging portfolio is designed for common vertical and horizontal packaging machines.

That turns machine compatibility into part of the environmental proposition.

If a paper solution can run through an installed line, adoption can happen through packaging procurement.

If it requires a completely new line, the decision becomes a capital-investment project.

Those are very different sales cycles.

Paper has to behave well before it can recycle well

This is where the fresh-produce sector becomes particularly demanding.

Paper performs very differently from conventional polyethylene film.

It responds differently to:

moisture,

tension,

folding,

puncture,

friction,

sealing,

and repeated mechanical stress.

Fresh produce adds another complication because the product itself contains water.

Cold-chain changes can create condensation.

Vegetables may carry surface moisture.

Packing environments may be humid.

Produce can push against the package during filling and transport.

A paper structure therefore has to maintain enough mechanical integrity until the consumer reaches the end of the supply chain.

Silbo says the paper used in its Reelbag has limited moisture absorption and that ventilation is provided through large mesh windows.

Those characteristics are relevant.

But application-specific testing remains essential.

A structure that works well for onions may not necessarily be appropriate for a product that requires much stronger moisture retention.

This is why a universal “plastic out, paper in” strategy would be a mistake.

PPWR itself recognizes the importance of the packing line

The regulation’s packaging-minimization requirements reinforce this point.

From 2030, packaging must be reduced in weight and volume to the minimum necessary while still maintaining functionality.

But PPWR’s methodology explicitly recognizes manufacturing and filling requirements.

Packaging may need sufficient:

mechanical strength,

impact resistance,

stability during conveying,

heat resistance,

closure performance,

and compatibility with packing-line speeds.

Product protection is also an explicit performance criterion, including protection against moisture loss, physical damage, oxidation and deterioration.

That is significant for fresh produce.

Europe’s packaging rules do not require companies to remove material until the package stops working.

They require companies to justify the material needed for the package to perform.

That creates a more engineering-led approach to minimization.

Food waste can overwhelm small packaging savings

The fundamental purpose of fresh-produce packaging is still to deliver saleable food.

That sounds obvious.

It becomes important when environmental targets focus heavily on packaging mass.

Consider a package that reduces packaging material significantly but increases bruising, moisture loss or spoilage.

The environmental calculation becomes much less attractive.

The resources embodied in the food itself have already been consumed:

land,

water,

fertilizer,

energy,

harvesting,

cooling,

processing,

and transport.

If the product is discarded, reducing a few grams of packaging may not compensate for the additional food loss.

PPWR’s own minimization framework recognizes prevention of product damage, loss, deterioration and waste as part of the package’s required functionality.

For produce packers, this means future packaging trials should measure more than packaging weight.

They need to measure what happens to the product.

Does it lose moisture faster?

Does bruising increase?

Does shelf life change?

Does ventilation remain sufficient?

Does condensation develop?

How many packs fail during distribution?

Those questions belong inside a sustainability assessment.

Ventilation could become one of paper’s most important design variables

Fresh produce packaging often needs airflow.

This is why mesh bags and perforated structures are common for potatoes, onions, citrus and similar crops.

Silbo addresses this through combinations of paper and mesh.

Its Mr Paper range includes structures using linen or viscose mesh, as well as transparent cellulose windows and ventilation openings.

That represents an interesting design shift.

Instead of relying entirely on the barrier properties of one continuous film, the package can use different components for different functions.

Paper supplies:

printability,

structure,

and the primary package surface.

Mesh supplies:

airflow,

visibility,

and flexibility.

But the end-of-life question then becomes more complicated.

Are the materials separable?

Do consumers know where the package belongs?

Can the complete structure be processed through the intended recycling route?

Silbo describes Mr Paper as designed for easy segregation and recycling.

That is a useful design objective.

But without application-specific independent recyclability data, it would be too broad to describe every Mr Paper construction as automatically recyclable in every European market.

The final structure still matters.

“Paper” will increasingly have to mean something technically precise

This is likely to become a wider issue under PPWR.

The packaging market has accumulated broad descriptions such as:

paper-based,

fibre-based,

plastic-free,

recyclable,

compostable,

and renewable.

Those terms can conceal substantial differences in construction.

A package that is 95% paper with a thin functional coating is very different from one that is 60% paper laminated to a thick polymer film.

Both might once have been described commercially as paper packaging.

Regulation is pushing the industry toward much more precise material definitions.

The 5% interpretation for the Annex V bans is an example.

End-of-life claims will increasingly require similar precision.

What exactly is in the package?

Can the components separate?

Which waste stream accepts it?

What happens during pulping?

What happens to the mesh or window?

That means paper suppliers cannot compete only by increasing the percentage of fibre.

They need to engineer structures that work inside real collection and recycling systems.

The best answer may sometimes still be mono-material plastic

Silbo makes an important point in saying there probably will not be one universal sustainable packaging material.

That is consistent with how PPWR itself is structured.

Some applications affected by the specific 2030 restrictions will need to leave single-use plastic.

Many other packaging applications will continue using plastic.

For those packages, moving toward a highly recyclable mono-material PE or PP structure may produce a stronger overall result than forcing a paper substitution that requires complex coatings or performs poorly.

Silbo itself continues to work across paper, mono-material films, cellulose, meshes and compostable structures rather than treating paper as its only strategy.

That matters.

A packaging manufacturer that sees regulation only as an opportunity to sell a preferred material may miss the larger change.

The market is moving toward application-specific eco-design.

The correct material depends on:

the product,

the machinery,

the logistics chain,

and the local end-of-life route.

Shorter packaging runs introduce another type of material waste

Silbo’s investment in digital printing adds a second dimension to this transition.

Fresh-produce packaging has unusually fragmented demand.

Different farms.

Different retailers.

Different languages.

Different countries of origin.

Seasonal promotions.

Varieties.

Private labels.

Export customers.

That can create many artwork versions with relatively small volumes.

Conventional flexographic printing remains highly efficient for long runs.

But making printing plates and producing large minimum quantities can become less attractive when each design is required only in small volumes.

Silbo has added an HP Indigo 200K alongside its existing flexographic capabilities.

Digiprint, which supplied the equipment, and HP’s Poland and Baltics country manager described the sale as the first HP Indigo 200K in Poland when it was announced in 2025.

The sustainability relevance here is not that digital printing is automatically environmentally superior.

That depends on the job.

Its operational value is the ability to produce shorter runs without conventional plates and to change designs rapidly.

Obsolete packaging is a largely invisible waste stream

This becomes important when packaging artwork changes.

A company may have thousands of unused printed packages sitting in inventory when:

a promotion ends,

a product origin changes,

a regulation changes,

a retailer updates branding,

or demand is lower than forecast.

The physical package may be perfectly usable.

Commercially, it has become waste.

Digital printing can reduce that risk by making smaller production batches economically feasible.

Fresh-produce packaging is particularly exposed because demand itself can be seasonal and variable.

That changes the definition of material efficiency.

It is not only:

How many grams are in each package?

It is also:

How many packages were manufactured but never used?

The most lightweight package imaginable still creates unnecessary environmental impact if large volumes become obsolete before reaching the packing line.

PPWR could increase packaging SKU complexity before it reduces it

There is another practical consequence of regulation.

PPWR aims to harmonize packaging rules across the EU.

But fresh produce will still operate across different:

products,

countries,

retail specifications,

consumer expectations,

and local recycling systems.

Member States can also establish exemptions to the under-1.5 kg fresh-produce restriction under the circumstances defined by the regulation.

That means produce companies may not simply migrate from one common plastic pack to one common paper pack.

They could end up managing several packaging architectures.

One for one product.

Another for a moisture-sensitive product.

Another for a specific national exemption.

Another for a retailer requesting a plastic-free structure.

Another for a market with different collection infrastructure.

That increases the value of short-run printing and flexible converting.

Regulatory simplification at the policy level can still create operational complexity at the packaging plant.

Machinery compatibility could separate the winners from the prototypes

The sustainable-packaging industry produces many technically interesting prototypes.

Far fewer reach high-volume packing operations.

Fresh produce is particularly unforgiving because margins are tight and packing speeds matter.

A grower or packhouse cannot easily accept:

frequent web breaks,

slow filling,

manual intervention,

inconsistent seals,

or substantially higher damaged-product rates.

This is why Silbo’s emphasis on packaging designed for existing automated lines deserves more attention than the material story alone.

The commercial breakthrough for paper produce packaging will not occur when somebody proves that a paper bag can hold potatoes.

That is easy.

It occurs when the paper bag can be supplied by the million, fed automatically, printed consistently, sealed reliably and moved through the entire distribution chain without creating a productivity penalty large enough to send the packer back to plastic.

Industrial runnability is what converts sustainable packaging from a demonstration into infrastructure.

PPWR may ultimately reward simpler packaging architectures

The broader direction of travel is becoming clearer.

Use less material.

Remove unnecessary layers.

Avoid incompatible components.

Use functional coatings only where needed.

Design with recycling in mind.

Protect the product sufficiently.

And make the package work on existing or economically viable production equipment.

That favors simpler structures.

But simple should not be confused with primitive.

A low-material paper package capable of replacing a high-performance plastic bag may require sophisticated:

paper engineering,

adhesive placement,

printing,

mesh integration,

converting,

and packing-line control.

In other words, simpler packaging can require better engineering.

Fresh produce could become an early test of whether PPWR works as intended

The fruit-and-vegetable restriction will be one of the most visible changes introduced by PPWR from 2030.

Consumers will notice it.

Retailers will have to change purchasing specifications.

Growers and packhouses will have to qualify alternatives.

Packaging suppliers will compete to redesign familiar bags, trays and nets.

The policy objective is straightforward: reduce unnecessary single-use plastic.

The industrial test is harder.

Can that reduction occur without increasing:

food loss,

material use elsewhere,

packing costs,

or operational waste?

The exemptions built into PPWR suggest lawmakers recognize that tension.

They allow plastic packaging to remain in specified circumstances where functions such as water-loss prevention, protection from physical shocks or microbiological safety require it.

That prevents the rule from becoming a simplistic material ban.

It also raises the standard for every alternative.

Silbo’s strategy points toward what comes after material substitution

The most significant part of Silbo’s positioning is therefore not Mr Paper alone.

It is the company’s refusal to frame one material as the answer to every application.

It continues working with paper.

Mono-material plastics.

Cellulose.

Natural and viscose meshes.

Compostable materials.

Flexographic printing.

Digital printing.

The logic is that the package should begin with the application and work backward toward the simplest functional structure.

That may sound less dramatic than announcing that plastic is being replaced.

It is probably much closer to where European packaging is heading.

Because the regulatory question is becoming less about what the front of the package appears to be made from.

It is becoming a systems question:

How much material?

Which materials?

Why are they there?

Can the packing line process them?

Do they protect the product?

Can they be collected and sorted?

And what happens to them afterwards?

The real 2030 transition is from material choice to packaging architecture

This is why the fresh-produce sector could become one of PPWR’s most useful case studies.

The obvious interpretation is that regulation will create a market for paper.

It will.

But that is only part of the story.

The deeper change is that packaging suppliers will increasingly have to justify the complete architecture of the pack.

A paper substrate does not automatically make the structure compliant.

A recyclable polymer does not automatically make it appropriate.

A compostable material does not automatically solve collection.

A lighter package is not better if the produce spoils.

And a laboratory success is not commercially useful if a packing line cannot run it.

For fresh-produce companies preparing for 2030, the safest strategy may therefore be not to ask:

What material replaces plastic?

But:

What is the simplest structure that keeps this specific product saleable, runs efficiently on the required machinery and has a defensible end-of-life route?

That is a much harder question.

It is also the question PPWR is increasingly forcing the packaging industry to answer.

Last Updated on 16/09/2026 by Jota Machinery