Aline Maigret, Head of Policy at Zero Waste Europe, states: “The EU Bioeconomy Strategy sets ambitious goals, but achieving a circular bioeconomy requires careful design within planetary boundaries. For example, promoting bio-based packaging without tackling environmental pressures from intensive forestry and agriculture is a no-go.”
The strategy’s emphasis on material production rather than bioenergy is a positive step, and embedding cascading use as a practical requirement would ensure biomass is kept in high-value, long-life applications rather than being diverted to lower-value or short-lived uses. ZWE also welcomes the recognition of the Ecodesign for Sustainable Products Regulation (ESPR) as a framework to guide sustainable bio-based products.
Aline Maigret continues: “ZWE believes the strategy can be strengthened by acting on our six priorities: prioritising reusable products, ensuring chemical safety, protecting recycled content, managing biowaste effectively, guiding responsible material use, safeguarding ecosystems, and embedding circularity across all lead markets.”
To ensure the bioeconomy delivers genuine environmental benefits, ZWE calls on the Commission to:
- Prioritise reusable products and packaging: Single-use bio-based plastics cannot be treated as circular solutions as they replicate the negative impacts of fossil-based plastics at their end of life.
- Include rules on chemical safety of bio-based materials: Natural origin is not a guarantee of non-toxicity and circularity. Stronger product regulations are necessary to ensure plant-based materials do not contain hazardous chemicals that threaten human health and the environment.
- Ensure bio-based and ‘novel materials’ do not substitute recycled content in packaging: All new products should be developed in line with design-for-recycling criteria.
- Develop specific measures for biowaste management across the EU: Proper separate collection and management of biowaste remains a key priority to support compost and fertiliser production and reduce import dependencies
- Include demand-side measures on material use for both bio-based and non-bio-based materials.
- Ensure strong safeguards for nature preservation: In order to prevent biodiversity loss, pollution, and climate impacts from bio-based products, especially plastics.
ZWE encourages the European Commission to add measures that curb overall material consumption, restrict inefficient biomass applications and ensure safe and circular material cycles, in order to build a bioeconomy that truly delivers on its 2040 goals.






