What role does packaging transparency play in ESG governance?

Packaging transparency plays a central role in ESG governance by providing the verified, material-level data that sustainability frameworks require. Without clear disclosure of what packaging is made from, how it is designed for end of life, and what emissions its production generates, companies cannot meet their environmental reporting obligations or substantiate the claims they make to investors, customers, and regulators. The sections below unpack the specific questions that food industry professionals and sustainability teams are asking in 2026.

How does packaging transparency affect ESG reporting obligations?

Packaging transparency directly shapes a company’s ability to meet ESG reporting obligations because the data required by sustainability frameworks, material composition, recycled content, recyclability assessments, must come from verified packaging supply chain disclosures. Without that data, companies cannot complete auditable environmental reports or satisfy regulatory requirements.

The clearest example in 2026 is the EU Packaging and Packaging Waste Regulation (PPWR), which has applied across all 27 EU member states since 12 August 2026. Under PPWR, manufacturers must issue a Declaration of Conformity for each packaging type placed on the EU market. Supplier self-declarations are not sufficient, verified test results, recycler certificates of origin, and full material breakdowns are required. Companies that have historically managed packaging compliance market by market now face a single, unified standard.

This packaging data maps directly to ESRS E5, the governing standard for circular economy and waste management under the EU’s Corporate Sustainability Reporting Directive (CSRD). Companies that build a verified data baseline for PPWR simultaneously satisfy much of their CSRD disclosure obligation. The same structured data infrastructure is also expected to serve the Digital Product Passport framework anticipated around 2027. One investment in packaging transparency, in other words, supports multiple regulatory obligations at once.

Even companies not directly in CSRD scope face indirect pressure. Following the CSRD Omnibus simplification adopted in early 2026, mandatory scope was narrowed primarily to companies with more than 1,000 employees and over €450 million in net turnover. But smaller suppliers may still be asked by their CSRD-reporting customers to provide packaging data up to the level of the Voluntary Standard for SMEs. The direction of travel for packaging transparency has not reversed, it has simply reached further into supply chains.

What packaging metrics do ESG frameworks actually measure?

ESG frameworks measure packaging performance through a defined set of material-level metrics: the share of recycled and renewable raw materials used, recyclability rates and end-of-life design, waste quantities by stream and composition, and the greenhouse gas emissions associated with packaging production and transport. These are not voluntary disclosures, under ESRS E5, they are required for companies for which packaging is a material topic.

For food businesses, packaging is almost universally material. ESRS E5 requires three categories of disclosure. Resource inflows cover the weight and share of recycled and reused materials in products and their packaging. Resource outflows cover whether packaging is designed according to circular economy principles, recyclable, reusable, or compostable. Waste disclosure covers total quantities generated, broken down by material type and processing method.

Packaging emissions also feed into Scope 3 greenhouse gas reporting. Supply chain Scope 3 emissions are, on average, significantly higher than a company’s own operational emissions, and packaging material volumes are a direct input to that calculation. ESG procurement platforms including EcoVadis and CDP now incorporate Scope 3 data as part of supplier assessment processes, meaning that a food producer’s packaging disclosure quality affects how its suppliers are scored, and vice versa.

The ESRS framework is being simplified under the Omnibus process, with a draft revised delegated act published for consultation in mid-2026 targeting adoption around September 2026 and application from financial year 2027. Until that revision is formally adopted, the current ESRS Delegated Regulation remains the applicable law. The simplification reduces mandatory datapoints but does not eliminate the core packaging metrics, it refines how materiality is applied, not what is measured when packaging is material.

Key metrics that sustainability teams should be tracking include: percentage of recycled content, recyclability grade under PPWR’s A to E grading system, share of fossil-based versus renewable raw materials, end-of-life disposal pathways, and plastic reduction measurement against a verified baseline.

Why are regulators tightening packaging disclosure requirements?

Regulators are tightening packaging disclosure requirements because voluntary commitments have not delivered the pace of change needed to meet waste reduction and climate targets. Binding rules are replacing guidance because the packaging sector generates substantial volumes of hard-to-recycle waste, relies heavily on fossil-based plastics, and has historically used inconsistent national labelling that made circular systems difficult to operate at scale.

The PPWR sets binding waste reduction targets, 5% by 2030, 10% by 2035, and 15% by 2040, against a 2018 baseline, alongside a target for 100% recyclability of all packaging placed on the EU market by 2030. To make those targets enforceable, regulators need packaging data they can verify. Disclosure requirements are the mechanism that makes the targets measurable.

The regulation also introduces a graded recyclability system running from Grade A to Grade E. From 2030, only Grades A through C may be placed on the EU market. From 2038, only Grades A and B remain. These thresholds require companies to know, and prove, exactly how recyclable their packaging is, which in turn requires transparent material composition data from the full supply chain.

On the labelling side, PPWR harmonises the inconsistent national rules that have made it difficult for consumers and waste processors to sort packaging correctly. From August 2028, harmonised sorting labels and material composition pictograms become mandatory EU-wide, replacing systems like France’s Triman with a single standard. Separately, from 27 September 2026, the EU’s Empowering Consumers for the Green Transition Directive (ECGT, Directive EU 2024/825) prohibits generic environmental claims, terms like “eco-friendly,” “green,” or “climate friendly,” unless substantiated with specific, verifiable evidence. There is no transition period for existing products already in distribution.

The practical effect is that packaging disclosure has moved from a reputational consideration to a legal prerequisite. As the PPWR regulatory overview from Latham & Watkins makes clear, non-compliance carries direct commercial consequences including market bans, product recalls, and financial penalties.

How can fibre-based packaging improve a company’s ESG score?

Fibre-based packaging improves a company’s ESG score by replacing fossil-based raw materials with renewable or recovered alternatives, reducing plastic volumes in the supply chain, and providing independently verifiable data on recyclability and material origin, all of which feed directly into the metrics that ESG frameworks measure and score.

The core ESG benefit is material substitution. Independent life cycle assessment research shows that coated paper packaging achieves substantially lower greenhouse gas emissions than multilayer plastic films, with some peer-reviewed studies finding reductions in the range of 34 to 62%, because cellulose fibre has a significantly lower carbon intensity than fossil-based polymers. Switching to a fibre-based format replaces fossil raw materials with renewable or recovered alternatives, which reduces the Scope 3 emissions attributable to packaging materials and strengthens a company’s position under ESRS E5 resource inflow disclosures.

At Jospak, we have engineered the Jospak® cardboard tray to make this transition practical rather than theoretical. The tray reduces plastic use by at least 85% compared to a conventional rigid plastic alternative, and its design, a fibre-based shell with a separable inner barrier film, means the cardboard and film can be sorted and recycled through existing collection systems. That separation is what makes the tray compliant with PPWR’s Design for Recycling principle, which requires packaging to enable secondary raw materials to substitute primary raw materials from 2030 onwards.

For sustainability teams building their ESG reporting data, the certifications attached to a packaging supplier matter as much as the product specifications. Our FSC® Chain of Custody certification (FSC® C151779) provides independently audited evidence of responsible fibre sourcing, while our BRCGS Packaging certification at AA+ grade covers food safety and quality. Holding both gives buyers documented evidence across two separate audit frameworks, the kind of third-party substantiation that makes ESG reporting defensible rather than aspirational.

Fibre-based packaging also supports the plastic minimisation requirements under PPWR. Because the cardboard shell provides structural rigidity, the tray uses a very thin inner liner rather than a full plastic structure, which reduces total packaging weight and material volume per unit, directly relevant to the binding weight and volume minimisation obligations that apply from 2026 onwards.

What are the risks of greenwashing in packaging ESG claims?

The risks of greenwashing in packaging ESG claims are now legal, not just reputational. From 27 September 2026, the EU’s Empowering Consumers for the Green Transition Directive (ECGT) prohibits generic environmental claims, including “eco-friendly,” “green,” “sustainable,” “biodegradable,” and “carbon neutral,” unless substantiated with specific, verifiable evidence. Non-compliance does not require a finding of consumer deception; the prohibition applies automatically.

The scope of the ECGT is broad. It covers environmental claims in business-to-consumer contexts, and the European Commission’s guidance confirms it applies to existing products and packaging already manufactured, ordered, or distributed before the application date. There is no transition period for old stock. Every piece of packaging, every product description, and every advertisement must comply from 27 September 2026 onwards.

It is important to distinguish the ECGT from the proposed EU Green Claims Directive, which was a separate legislative file. That proposal was withdrawn by the European Commission in 2025 and is listed as blocked as of 2026. The binding framework for environmental claims is the ECGT, not the withdrawn proposal. Companies should not conflate the two.

The practical implication for food packaging producers is that vague sustainability language must be replaced with specific, documented claims. Saying a tray is “made from renewable fibre sourced from FSC-certified forests” is defensible. Saying it is “eco-friendly” without substantiation is not. Third-party certifications, FSC for fibre origin and chain of custody, BRCGS for food safety and packaging quality, provide the independently audited evidence base that makes sustainable packaging claims legally robust rather than legally exposed.

The greenwashing risk also extends to future commitments. The ECGT restricts unsubstantiated claims about future environmental performance. If a company commits publicly to a packaging sustainability target, it needs a credible, documented pathway to achieve it, not a general aspiration.

How should companies communicate packaging sustainability to stakeholders?

Companies should communicate packaging sustainability to stakeholders by leading with specific, verified data rather than general claims, using third-party certifications as the foundation of credibility, and tailoring the format of that information to each audience, investors, procurement teams, and consumers each need a different level of technical detail, but all need the same underlying facts to be accurate and auditable.

The distinction between ESG reporting and ESG communication matters here. Reporting is the technical process of gathering data to meet regulatory or investor requirements, structured disclosures under frameworks like ESRS E5, GRI, or CDP. Communication is how that data is presented to different audiences in ways they can act on. Both require the same verified data foundation, but the format and emphasis differ significantly.

For investor and procurement audiences, the most effective communication anchors sustainability claims to independently verified evidence. A 2025 PwC survey found that a strong majority of investors report that sustainability metrics directly improve their confidence in a company. What builds that confidence is not aspirational language but documented proof, recyclability assessments, recycled content percentages, material composition data, and the certifications that verify them. Procurement teams at major retailers increasingly require this documentation as a condition of supplier listing, making cardboard packaging sustainability credentials a direct commercial consideration, not just a reporting exercise.

For broader stakeholder communication, the most credible approach combines transparency about current performance with honesty about the steps still ahead. Reporting formats that include executive summaries, clear methodology explanations, and baseline comparisons allow different audiences to engage at the level of detail appropriate to them. Visual data representations help make complex packaging metrics accessible without sacrificing accuracy.

Suppliers who hold multiple certifications, such as FSC for fibre sourcing and BRCGS for food safety, give buyers a more complete picture of overall reliability across independent audit frameworks. As environmental compliance requirements expand under PPWR and CSRD, brands increasingly need documentation that their supply chain choices will withstand regulatory scrutiny. Packaging suppliers who can provide that documentation are not just meeting a compliance requirement, they are strengthening supply chain trust in a way that translates directly into commercial relationships.