Paper-Based Flexible Packaging:

What the Ellen MacArthur Foundation Report Really Says

The Ellen MacArthur Foundation just released a report that has packaging circles talking. Paper-Based Flexible Packaging: The Role It Could Play in Tackling Small-Format Flexible Plastic Pollution in Markets with High Leakage Rates is detailed, evidence-based, and its conclusions are more conditional than the headline suggests. I have read it carefully, and I want to give you a clear picture of what it does and does not tell us, and what it actually means for a brand selling packaged goods.

The Specific Problem This Report Is Solving

The Ellen MacArthur Foundation is not talking about flexible packaging broadly. The report focuses on one narrow but serious problem: small-format flexible packaging such as sachets, wrappers, pouches and small pillow bags sized roughly A5 or smaller, in countries where waste collection systems are weak or inconsistent.

Think single-serve shampoo sachets in Indonesia, condiment wrappers in the Philippines, and cooking oil sachets in India. These are among the fastest-growing packaging formats globally, and in markets where informal waste collection is the norm, they rarely get recovered. The Foundation reports that flexible plastic packaging accounts for 80% of plastic packaging entering the ocean in these high-leakage countries.

The economics tell you why: collection rates for small-format flexible packaging sit below 5% in India, and under 1% for multilayer plastic flexibles in Indonesia. A waste picker would need to collect more than 60 small sachets to match the value of a single PET bottle. That is not a behaviour or awareness problem, but an economics problem, and no amount of good intentions changes the underlying maths.

The report is also explicit about its scope: markets with formal collection systems and lower leakage rates are not the primary focus. Countries such as Australia, the UK, and the US sit outside that scope. That does not mean the report is irrelevant here, but it does mean brands in these countries need to read it carefully before drawing conclusions about their own packaging decisions.

What the Report Proposes and Under What Conditions

The Foundation's argument is careful and conditional. Paper-based flexible packaging could help reduce persistent plastic pollution in high-leakage markets, but only if it is "responsibly designed" and used as part of a broader strategy.

The core logic is straightforward: if packaging is likely to end up in the environment regardless of how well it is designed, then a material that biodegrades or can be more easily recycled as collection systems improve is preferable to one that persists for decades. Paper, under the right conditions, has that advantage over plastic film.

The report sets out six criteria that paper-based flexible packaging must meet to claim genuine environmental benefit. These are not suggestions; the report is explicit that packaging meeting all six criteria does not yet exist at the scale, cost, or performance needed for most applications.

The six criteria are:

1. Responsibly sourced: to avoid contributing to forest degradation.

2. Responsibly produced: to minimise pressure on climate and water resources.

3. Meets technical, economic and consumer needs: to be viable in practice.

4. Recyclable locally and supported by efforts to scale up collection infrastructure.

5. Avoids hazardous chemicals and persistent plastic pollution, including polymer coatings or additives that undermine biodegradability or introduce chemical risks.

6. Fits within a broader, socially inclusive circular economy strategy: material substitution alone is not a solution.

   
   

That sixth criteria is the one most likely to be overlooked. The report frames paper as one tool within a larger strategy that includes reducing reliance on small-format formats altogether, scaling reuse models, and building collection infrastructure. A material switch that sidesteps those other elements delivers little real benefit.

The claim that actually can make things worse

The Foundation recommends that brands not communicate biodegradability on packaging. The reason is grounded in emerging evidence: some consumers may be more likely to discard packaging in the open environment if they believe it will break down. The report points out that even accounting for increased littering, biodegradable packaging still results in substantially less accumulated waste over time. The principle holds: packaging should never be intended to end up in the environment, and on-pack biodegradability claims risk sending the wrong signal.

I have seen this phenomenon happen during beach clean-ups; the small ketchup sachets, toothpick packaging and cutlery are the most common forms of trash in the environment.

The guidance instead is to focus consumer communication on clear, specific disposal instructions that reflect what local collection and recycling systems can actually handle. That is good practice regardless of material, and it is a useful reminder that the story you tell on the pack has real downstream consequences.

The Deforestation Risk Deserves More Attention

Switching from plastic to paper sounds like a straightforward environmental win. The risks that come with paper deserve more attention than they typically get.

If demand for paper-based flexible packaging scales rapidly without careful fibre sourcing, it adds pressure to forests that are already under significant stress. The report notes that globally, wood demand already exceeds responsible supply. Logging currently accounts for roughly a quarter of global tree cover loss. Paper production and other short-lived fibre products already account for nearly a fifth of all logging, approximately 5 billion trees per year, and demand is forecast to rise.

A large-scale shift from plastic to virgin paper-based alternatives would add to that pressure. That does not make paper the wrong choice. It makes responsible sourcing with FSC certification or equivalent a non-negotiable starting point, not an optional extra.

The report is equally clear on a design point that is easy to miss. Paper packaging with non-biodegradable polymer coatings or liners does not behave like paper in the environment. The Foundation's modelling shows that packaging with a non-biodegradable liner and a biodegradable material results in environmental mass levels similar to those of conventional non-biodegradable plastic, because the liner significantly slows biodegradation. The material composition of the whole package matters, not just the substrate.

What This Means If Your Brand Uses Paper-Based Flexible Packaging

Here is the thing worth understanding before you draw any conclusions from this report for your own business.

The report is written for a very specific context: countries where packaging routinely ends up in rivers, oceans and streets because there simply is not enough infrastructure to collect it. 

If your brand sells into markets with functioning rubbish collection and recycling systems, such as Japan, the UK, Australia and most of the EU, that is a different situation. The environmental risk is different, and the solution is different too.

In those markets, flexible plastic packaging mostly ends up in landfill, not because it leaks into the environment, but because the systems needed to sort and recycle it do not yet exist at scale, but switching the material from plastic to paper does not automatically fix that. Paper that cannot be recycled through local systems, or that uses coatings which contaminate paper recycling, just creates a different version of the same problem.

So before reaching for a material switch, the more useful questions are: 

• What countries does this product serve?

• Where does this packaging actually end up after use?

• Can local systems genuinely recover it? 

• Is there a way to simplify or eliminate this format before changing what it is made from?

  
  

The report makes this point directly: reducing reliance on small-format flexible packaging altogether, through larger formats, refill models, or packaging-free options, should always come before a material substitution. That logic applies everywhere, not just in high-leakage markets.

My Read on the Report

The Ellen MacArthur Foundation has produced a rigorous and genuinely useful piece of work. It does not oversell paper as a solution but sets clear conditions, acknowledges real limitations, and positions paper as one tool within a system-level response to a specific, well-defined problem.

The report is worth reading in full, I have linked it below. What I would caution against is reading it as a signal that switching to paper-based flexible packaging is the next obvious step for brands. The conditions under which paper delivers genuine environmental benefit are demanding, and several of them are not yet achievable at commercial scale for most applications.

Sustainable packaging is a design problem, the material is one variable. The source of that material, how it performs in use, what systems it enters at the end of life, and what claims you make about it on pack, all of those variables matter too.

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Read the full EMF report here