Plastic to paper packaging: four big buyers' fibre switches, and the fee and PFAS tests each one must pass

Why plastic to paper packaging is now a fee question

A fibre switch used to be a sustainability decision with a cost line attached. In 2026 it is also a fee decision, because Europe’s packaging schemes now price materials far apart and the PPWR has tightened what a paper pack may contain. Three numbers decide the outcome for any pack: the weight rate of the plastic it replaces, the weight rate of the paper it becomes, and how much heavier the paper version is.

The weight ratio matters more than most briefs assume. Paper is denser than film and needs more mass for the same strength, so a flow-wrap or tray in paper is usually heavier than its plastic predecessor. SPI analysis: the fee per pack falls only when the weight ratio stays below the ratio of the two rates. SPI calls that the break-even weight ratio, and Exhibit 2 sets it out for the plain paper lines.

The spread is wide because the two schemes price paper very differently. CONAI cut its paper base from EUR 65 to EUR 45 a tonne on 1 October 2025 and raised its plastic bands on 1 October 2026, so the gap widened on both sides within a year (SPI Italy fee-market note, from CONAI releases of 7 July 2025 and 25 May 2026). Citeo’s paper and board line, at EUR 258.1 a tonne, is the second highest of the nine plain paper rates in SPI’s euro scheme comparison; how that rate compares across nine schemes is covered in SPI’s piece on paper and board fees in euro schemes, which this piece does not repeat.

France: Citeo's rates and the coating on the paper

Citeo charges each material in a pack at its own weight rate, in euro cents per kilogram, which SPI converts to EUR per tonne (Citeo guide 2026, updated 22 June 2026). A paper pack with a plastic coating is therefore priced partly at the paper rate and partly at a plastic rate, so the coating’s weight share drives the result (Exhibit 3).

Two details of the Citeo guide shape a fibre switch. First, paper with more than 50% recycled fibre earns a 10% cut on its paper weight part, and units changed after 30 September 2026 count only from the 2027 declaration (SPI France fee-market note, from the 2026 guide). Second, a unit that carries a malus for disrupting recycling cannot claim any bonus at all, so a paper pack that sorting centres reject gives up the recycled fibre saving too.

Italy: CONAI's fibre bands make paper cheap, and composites less so

CONAI grades paper packaging by its fibre share, with a lower rate for composites certified under the Aticelca 501 method, and grades plastic by whether it can be sorted and recycled and from which circuit it comes (SPI Italy fee-market note, from the CONAI 2026 guide). The 2026 table runs from EUR 45 a tonne for single-material paper to EUR 285 for type D composites below 60% paper, against EUR 856 for plastic band B2.2 and EUR 922 for band C from 1 October 2026 (CONAI 2026 table).

The CONAI fee also reaches the buyer by a different road. It is applied at the first transfer of empty packaging inside Italy, by the last producer or trader of that packaging when it sells to the first user, and it is shown on the invoice (SPI Italy fee-market note, from CONAI’s EPR fee pages). A brand switching a tray from PET to paper in Italy therefore sees the saving on its converter’s invoice, not in its own declaration, unless it imports packed goods and declares them itself.

The UK: where coated paper costs more than plastic

UK packaging EPR prices household packaging by material and by recyclability rating, in GBP. PackUK’s year 2 illustrative fees, published on 16 December 2025 and updated on 19 December 2025, set paper and board at GBP 190 green, GBP 210 amber and GBP 250 red a tonne, fibre-based composite at GBP 475, GBP 525 and GBP 630, and plastic at GBP 415, GBP 455 and GBP 545. The fees are illustrative, rounded to the nearest GBP 5, and still unconfirmed on 4 November 2026.

The classification line is now written down. RAM 2027 guidance says paper or board packaging with plastic content greater than 5% by mass must be assessed as fibre-based composite, and lists dry food packs with an inner barrier and plastic-coated moulded fibre trays among the non-liquid cartons in that class. A non-liquid carton is amber at application if non-paper content exceeds 10% by weight, and red if it exceeds 15% at collection or is laminated with plastic on both sides without clear disposal guidance (RAM 2027 guidance, updated 20 August 2026).

A framework: four kinds of fibre switch

The four buyers’ switches fall into four kinds, set by two questions: does the paper touch food, and does the pack need a barrier against oxygen, moisture or grease? Each kind meets a different rule first (Exhibit 6).

Kind A, plain fibre swaps. These are the easiest on fees, because the pack stays on the plain paper line: EUR 45 a tonne in Italy and EUR 258.1 in France. But they are food-contact packs, and the Commission’s guidance states that there are no exceptions for packaging containing recycled material, which matters for trays and bags made from recovered fibre (Commission Notice C/2026/3084, as quoted in SPI’s PFAS food-contact piece).

Kind B, barrier paper. Coffee is the hard case. Nestlé’s 2024 release says its high-barrier paper refill for NESCAFÉ in the UK cuts packaging weight by 97% compared with the glass jar, which is a refill against a jar, not paper against film. For fee purposes the question is the plastic share: above 5% the UK classes the pack as a fibre-based composite, and in Italy every step below 95% fibre moves it up a band.

Kind C, grease-resistant fibre. Quick-service packaging is the PFAS front line, because grease resistance was historically where fluorinated coatings were used. McDonald’s sets an internal screen for packaging with oil and grease barrier coatings at 100 ppm of total organic fluorine (McDonald’s packaging page).

Kind D, outer packs. Where the paper holds wrapped goods, PFAS exposure is lower and the fee and weight test decides. Mondelēz’s Cadbury Heroes tub holds individually wrapped sweets, and its paper multipack bags hold biscuit packs.

Scenarios: one million wrappers in paper

SPI priced one pack, a confectionery flow-wrap, through three paper versions in each scheme, in EUR for France and Italy (Exhibit 7) and in GBP for the UK (Exhibit 8). The plastic wrapper is a 3 g polypropylene film; the paper versions are 1.5, 2.0 and 3.0 times heavier, with more coating as weight rises. Weights are SPI assumptions, not any company’s specification.

SPI calculation: the base case saves EUR 603.06 per million wrappers in France and EUR 2,148.00 in Italy. Each figure is a saving inside one scheme, not a total across the two. At one million units the sums are small, but they scale in a straight line with volume, so a line of 100 million wrappers carries 100 times the gap.

Trays: what Mondelēz's switch means at French rates

Rigid trays are a cleaner case than wrappers, because a paper tray often needs no plastic layer. Citeo charges rigid PET packaging (tarif 6.3.3) at EUR 840.1 a tonne, so a tonne of PET tray can become up to 3.25 tonnes of plain paper tray before the French weight fee rises (Exhibit 9).

PFAS-free paper packaging: what the limits demand of a fibre switch

The PFAS limit is the rule that turns a fibre switch from a design task into a compliance file. Article 5(5) of Regulation (EU) 2025/40 provides that from 12 August 2026 food-contact packaging shall not be placed on the market if it contains PFAS at or above 25 ppb for any PFAS by targeted analysis, 250 ppb for the sum of targeted PFAS, or 50 ppm for total PFAS including polymeric PFAS (Commission Notice C/2026/3084, quoting the article; PR-EU-002 on the SPI Regulation Tracker).

Three points matter for a fibre switch, and SPI’s PFAS food-contact piece covers the test sequence in full. First, there is no period for running down stock: packaging placed on the market before 12 August 2026 may stay on the market, but anything placed after must comply, and filled packaging is placed on the market when it is filled (Commission Notice C/2026/3084). Second, the limits are framed by concentration, not material, so they apply to plastic as well, but paper is where fluorinated grease barriers were used. Third, the UK goes further on totals: RAM 2027 rates food packaging red above 25 ppb for any individual or total PFAS, one tenth of the EU’s 250 ppb sum limit on the face of the GOV.UK wording.

What the four buyers report, and what they leave out

Each company reports its fibre switches differently, and none publishes the full set of numbers a fee model needs: the paper tonnage added, the weight ratio and the plastic share of the new pack (Exhibit 11). The SPI Packaging Buyers Database holds each company’s profile, with sources.

Where composites and recyclability rules come next

The PPWR adds a third test to the two above. Its design-for-recycling criteria under Article 6 take effect on the later of 1 January 2030 and two years after the delegated acts, so barrier choices made in 2026 should be checked against them (SPI tracker, PR-EU-002 interactions, from Commission Notice C/2026/3084). How each euro scheme classifies and prices laminates and mixed packs today, including the 5% EU composite threshold and the 80% to 95% lines in the schemes, is set out in SPI’s piece on composite packaging EPR fees.

The Commission’s timeline also sets a review of the Article 5(5) PFAS restriction for 12 February 2030, and recital 21 asks the Commission to assess whether to amend or repeal it so that it does not overlap with other Union acts (SPI tracker, PR-EU-002, from the Commission timeline and Regulation (EU) 2025/40). SPI analysis: a buyer should plan on the limits staying until at least that review, because nothing in the texts SPI read suggests an earlier change.