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Mondi Group

Circular Solutions, created by empowered people, taking action on climate.

Lobbying Activity

Response to Circular Economy Act

6 Nov 2025

LS, Please find our feedback in the PDF attached Tim Werkhoven Group Head of Public Affairs Mondi Group
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Meeting with Ondřej Krutílek (Member of the European Parliament)

21 Oct 2025 · Future of bioeconomy in the EU

Response to Towards a Circular, Regenerative and Competitive Bioeconomy

20 Jun 2025

Mondis recommendations for the 2025 EU Bioeconomy Strategy: 1. Resolve forest policy fragmentation to harmonise conflicting objectives, reduce complexity and unlock bioeconomic growth 2. Make responsibly sourced fibre central to Europes clean industrial future and global competitiveness 3. Reinforce the role of multifunctional, actively managed forests in climate change mitigation and ecosystem resilience Forest policy and the EU Bioeconomy Strategy Background Forests are uniquely multifunctional in the context of Europes climate targets, industrial competitiveness, and regional development. Few resources make such a broad contribution to the EUs policy goals in these areas from supplying renewable wood fibre, absorbing carbon, and delivering vital ecosystem services, to anchoring rural communities, providing skilled jobs, and supporting Europes resource autonomy. This multifunctional role means that forest policy must combine ecosystem protection with the need to sustainably produce renewable materials that enable Europes transition to a competitive, lowcarbon economy. These commitments are complementary and getting the balance right is essential to the success of the EU Bioeconomy Strategy. But currently, a patchwork of EU and Member State bioeconomy regulations, frameworks, and incentives is creating contradictory objectives, administrative complexity, and unintended consequences for manufacturers of fibre-based products. Forest owners, managers, and industries are being pulled in different directions, limiting their ability to plan, invest, and contribute to the EUs policy goals. It is essential to align the EUs environmental, climate, and industrial agendas around a shared vision for sustainable forest use one that recognises the full value forests bring across society, the economy, and nature, rather than advancing one objective at the expense of others. The 2025 EU Bioeconomy Strategy provides a timely and appropriate platform to take stock of these competing pressures, harmonise objectives, and ensure that forest-based value chains are supported, rather than sidelined, in the clean industrial transition. Without this, Europe cannot build a credible bioeconomy that competes on the global stage. About Mondi Mondi is a global leader in packaging and paper. We employ 24,000 people in over 30 countries and operate across the entire value chain - from managing sustainable working forests to producing innovative products and solutions that contribute to the circular bioeconomy. Responsibly sourced wood fibre is the most important raw material for the packaging and paper solutions we produce. We are committed to promoting sustainable forest management and maintaining zero deforestation in our wood supply. Drawing on decades of experience, we collaborate across the forest sector to share expertise and support the development of strategies that help in the fight against climate change and nature loss. Further detail on these recommendations, including supporting evidence, is provided in the attached position paper.
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Meeting with Christine Singer (Member of the European Parliament)

26 Feb 2025 · Omnibus + Clean Industrial Deal

Meeting with Tiemo Wölken (Member of the European Parliament)

14 Oct 2024 · Exchange on Sustainability Policies (staff level)

Response to Review of the requirements for packaging and feasibility of measures to prevent packaging waste

19 Apr 2023

Mondi supports Commission proposal, but it still requires key improvements to reach full potential Mondi is a global manufacturer of a wide range of fibre-based and flexible packaging solutions, employing approximately 21.000 colleagues globally. Improvements in recycling infrastructure The main hurdle to boosting recycling is better sorting and collection of materials. Paper and board products already have an average recycling rate of 84% across the EU. Boosting recycling rates, particularly in the flexible and plastic sectors will be crucial to ensure sufficiently high amounts of high-quality post-consumer plastic recyclate. There should be clear mandates in the regulation that compel member states to prioritise collection, sorting and recycling infrastructure, without room for derogations. Recycled plastic content While we expect the quantity of PCR plastic to increase over the next few years, targets alone are not enough to ensure a functioning secondary raw material market. Infrastructure and consumer participation are key to PCR content uptake in plastic packaging, alongside enabling conditions. We need timely adoption of EU-wide PCR calculation rules that take a fuel-exempt mass-balance chain-of-custody approach into consideration to ensure new technologies, such as chemical recycling, can scale up. Also, we ask the EU Commission to ensure sufficient legal safeguards are in place if sufficient high-quality PCR is lacking in the marketplace, or material costs are too prohibitive. Finally, we are concerned about the unclear scope of the provision and recommend limiting the recycled content obligation to packaging consisting of plastics as their predominant material. Recycling and Reuse are complimentary concepts Mondi strongly believes that recyclability and reuse are complimentary concepts that when used correctly can contribute to the EUs path to circularity. Prioritising reuse is likely to disrupt established, well-functioning recycling systems in many member states. When deciding between recyclability and reuse, sound scientific evidence about environmental impacts of the product across its full life-cycle need to be the guiding principle. We ask that the Commission considers existing Design for Recycling guidance, such those established by CEFLEX and 4evergreen, and takes the latest evidence into account to ensure circular solutions are prioritised. A focus on reuse, particularly in applications where fibre-based packaging is proven to have a lower environmental footprint than reusable rigid plastic alternatives (e.g. e-commerce and take-away food), may work against the EU climate goals. Reuse in food and e-commerce applications will result in significantly more rigid plastic containers, with manufacturing and transport (between consumer, washer and vendor/filler) adding emissions that could be avoided with low carbon fibre-based packaging. Void space Mondi agrees that over-packaging is an issue. A one-size fits all void space limit of 40% ignores the realities of product dimensions, weight or fragility and how the main purpose of packaging is to protect its contents. We believe there should be flexibility to allow products to be packaged in a fit-for-purpose way that protects them in the best way possible. Restrictions on packaging formats Packaging plays a particularly vital role for fruit and vegetable packaging, protecting products from outside factors and preventing cross contamination. By proposing to ban all packaging for fruits and vegetables less than 1,5kg, as well as portion packs, the Commission overlooks unintended consequences for consumers health, as well as food security and waste. Conclusion There are clear opportunities for improvement in the proposed PPWR for it to reach its full circularity potential. This should be done by relying on sound scientific data and fostering investment in those products and technologies that have the lowest impact on the environment.
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