The true impact of virgin paper: Rethinking sustainable packaging for beauty brands

Packaging decisions are increasingly scrutinized in the cosmetics and personal care industry as environmental concerns and regulations intensify. With the growing trend of states like California implementing plastic bans, the industry is facing a shift toward alternative materials, including paper and more sustainable options.

However, new challenges emerge as companies navigate these changes, particularly the unintended consequences of transitioning to virgin paper. To understand the broader implications of these shifts and the steps cosmetics and personal care brands can take to adopt sustainable packaging practices, CosmeticsDesign spoke with Saloni Doshi, CEO and Chief Sustainability Officer at EcoEnclose. 

EcoEnclose, a leading sustainable packaging provider for over 50,000 eCommerce brands, helps brands implement more sustainable packaging that aligns with their broader business objectives. Since acquiring the company, Doshi has spearheaded the research, development, and launch of innovative packaging solutions – including options made with industry-leading levels of post-consumer waste and solutions incorporating next-generation inputs such as agricultural waste, hemp, and seaweed.

In this interview, Doshi discusses how brands can balance environmental responsibility with consumer expectations, explore innovative packaging materials, and stay ahead of evolving regulations.

CDU: With states like California banning single-use plastics, what immediate impacts have you seen on the consumption of virgin paper in the packaging industry?​

Saloni Doshi (SD)​: Many US states and municipalities are rolling out plastic bag bans or fees. We must address the environmental impact of single-use plastics but also consider the broader implications of total material bans. They drive up the use of other materials, and the rapid increase in demand for alternatives is not always met sustainably.

At EcoEnclose, we have seen this in action; businesses going plastic-free often look to paper packaging to fill the gap. In many cases, though, they're turning to virgin paper from unvetted sources, unaware of the environmental impact of this swap. Paper can be a great alternative, but being thoughtful about its source material is critical.

Every year, over three billion trees are cut down in the name of paper packaging (Canopy Planet), and I fear plastic bans will push this figure higher without appropriate countermeasures. Preserving primary forests is so important in mitigating climate change, and though it's possible to grow and harvest trees sustainably, surging demand for paper inevitably places immense pressure on intact forests.

CDU: How can cosmetics and personal care brands proactively address the rise in virgin paper consumption as they shift away from plastic?​

SD​: The first step is to maximize post-consumer waste and boost overall recycled content levels in paper packaging. Recycled content leverages existing materials and does not directly rely on logging. It also emits 74% fewer emissions, uses 52% less energy, requires 33% less freshwater, and has a 66% lower impact on ocean acidification than virgin paper.

I also encourage cosmetics and personal care brands to actively pursue the production of paper packaging made from next-generation materials such as wheat straw, miscanthus, and hemp. Long-term, I'd love to see a world in which these alternative paper inputs - derived from agricultural waste or restorative on-purpose crops - help diversify the fiber basket so we aren't exclusively reliant on trees for our paper.

CDU: You've advocated for fees on virgin paper to encourage using more sustainable materials. How would such a policy affect packaging choices for cosmetics and personal care brands?​

SD​: I advocate for packaging policies that recognize the complexities inherent to sustainability. As such, I propose that policies that ban or restrict the use of plastic bags also include measures to discourage the use of virgin paper as an alternative.

Introducing fees on virgin paper is one such approach that would act as a strong disincentive, pushing brands towards more sustainable materials. Crucially, these fees would act as an important countermeasure, mitigating the impact of plastic bag bans on other vulnerable packaging inputs like trees. The fact is that there are great alternatives out there – fees would simply give businesses a nudge in the right direction and ensure they make responsible choices when legislation forces them to change their approach.

The long-term implications would only be positive. Customers care about this stuff; a 2023 McKinsey report​ found that 90% of respondents rated the environmental impact of product packaging as somewhat, significantly, or significantly, an increase from the 75% result in 2020.

Ultimately, fees like this would encourage brands to make holistic, eco-conscious packaging decisions, audit their packaging choices, and show their customers that they're making a positive impact.

CDU: Can you provide examples of successful packaging alternatives for the industry that utilize high recycled content or next-generation materials like wheat straw, hemp, or miscanthus?​

SD​: Regarding paper packaging, options contain 100% recycled content and 95% post-consumer waste content. This PCW has been diverted from landfills, a crucial step toward true circularity.

But, beyond this, brands should also seek out emerging, innovative materials such as wheat straw waste and hemp. By using these options, businesses can catalyze their long-term market adoption.

Brands should also explore reusable bags made with 100% recycled content and durable enough to last hundreds of uses. Some retailers may even consider going fully bagless, encouraging customers always to bring their shopping totes.

CDU: You mentioned that current legislation often focuses too heavily on a product's end-of-life rather than its entire lifecycle. How can cosmetics and personal care manufacturers incorporate a whole lifecycle approach into their packaging?​

SD​: Brands can only clearly assess the impact of any given material if they consider its entire lifecycle. That includes the raw materials being produced or extracted, how and where we source them, and the impact of manufacturing packaging from them.

When making the big calls on packaging, I encourage brands to assess this entire life cycle and recognize that over 85% of packaging's impact generally comes from the early stages of a material's lifecycle.

CDU: What challenges do you foresee for beauty and personal care brands when balancing environmental impact with consumer expectations?​

SD​: I recognize that sustainability isn't the only factor brands must consider. It's often not even a top factor. Companies must consider their brand, aesthetics, budget constraints, operational needs, and retailer requirements.

While consumers do care about sustainability, many have other priorities, such as prestige, product quality, or cost.

This is why, through EcoEnclose, I take an EcoAlly approach. The best approach is to help brands crystallize their priorities and match them with the most eco-friendly packaging possible. I fundamentally believe in progress over perfection; it makes eco-packaging more accessible to all brands.

CDU: How can extended producer responsibility laws be expanded to better account for the entire lifecycle of packaging materials in the cosmetics and personal care sector?​

SD​: We need to highlight the beginning of a product's lifecycle; it's not considered enough, so opportunities to boost packaging sustainability are falling through the gap.

EPR legislation and other packaging regulations can sometimes be short-sighted because they focus on one problematic material or issue while ignoring or downplaying other considerations. But sustainability challenges don't exist in a vacuum—they are part of a complex system. Responsible, impactful legislation needs to acknowledge the knock-on effects of any decision.

I would like to see policymakers consider the bigger picture, consider the whole lifecycle of a packaging product, and implement measures that address the consequences of any material ban.

CDU: In your opinion, how should cosmetics and personal care brands navigate the evolving regulatory landscape around sustainable packaging?​

SD​: Again, a packaging provider understanding the business's needs is a huge help. Aside from this, though, it's important to consider the pace of legislation developments.

Five states have already passed packaging-related EPR legislation, and many others have bills in the works. In addition, dozens of states have passed laws banning plastic bags, polystyrene, PVC, and other problematic materials.

Additionally, states are passing truth-in-labeling legislation that increases scrutiny of end-of-life on-package instructions. Finally, the Federal Trade Commission's Green Guides should soon get a much-anticipated overhaul.

States and voters are paying more attention than ever to the impact of packaging, so brands need to get ahead of the curve.

There are tangible, productive steps brands can take right now.

Join the Circular Action Alliance​, the PRO selected to execute California and Colorado's EPR legislation (and likely to execute on other states policies as well). Audit your packaging suite and optimize components that aren't already readily recyclable.

Look for ways to increase post-consumer waste. Consider if and where reuse or refill models can make sense for your brand. Start budgeting for the fees brands pay into PROs as part of EPR implementation.

CDU: You've emphasized the need for innovation in diversifying the "fiber basket" for packaging. What are some of the most promising advancements in packaging materials for the beauty industry that you've seen?​

SD​: There are so many advancements! But when it comes to diversifying the fiber basket, one development I'm excited about is the use of agricultural waste.

Agricultural waste, such as cotton linters and wheat straw, can be a valuable paper source. In fact, in India, this waste already accounts for around 28% of the total feedstock used in the paper industry (PMC​).

It is developing in the US, and as it poses no risk to deforestation, is a natural byproduct, and doesn't threaten human health, it's an up-and-coming option.

CDU: What steps can cosmetics and personal care companies take today to be at the forefront of innovation in sustainable packaging?​

SD​: Businesses must reduce the negative environmental impact of their product packaging, but this approach will only take us so far. It is another thing to play an active role in developing future packaging materials.

Cosmetics and personal care brands with the resources to do so must invest in cutting-edge packaging innovations to make a genuinely positive ecological impact. By investing in developing next-generation materials, brands will set themselves apart as forces for good.

CDU: FSC-certified options are one route to mitigate deforestation, but how can cosmetics brands reduce their reliance on virgin paper while maintaining packaging quality and functionality?​

SD​: Brands that use virgin paper packaging must ensure their raw materials aren't logged from primary forests. Choosing FSC-certified paper is one way to do that. Brands can also reduce reliance on virgin paper by boosting post-consumer waste levels.

It's impossible to entirely banish virgin paper from paper packaging, as it cannot be endlessly recycled and must eventually enter the stream. However, increasing the levels of recycled content in packaging is critical in easing our reliance on virgin paper.

CDU: How can smaller beauty brands, which may have less access to alternative packaging materials, start making incremental changes towards more sustainable packaging?​

SD​: In some ways, small businesses are in a great position to move towards sustainable packaging. They are often more nimble than larger organizations, and because they are often closer to their customers, they are in a solid position to communicate transparently about their sustainability goals.

There's no one-size-fits-all approach, but if small businesses prioritize this now and do the necessary research, they can establish a crystal-clear packaging strategy ready to act as their business grows.

CDU: How can cosmetics and personal care companies effectively communicate the importance of packaging sustainability to their consumers, especially when it involves more complex materials like agricultural or post-consumer waste?​

SD​: We need to credit consumers for being increasingly eco-conscious. That being said, there are also lessons to learn from California's Truth in Labelling legislation, which will come into effect in 2025.

Retailers must include accurate, digestible recycling information on their packaging, which will help consumers become more familiar with packaging sustainability.

Honesty, transparency, and clarity of information are critical. Blanket statements such as "recycled" or "post-consumer waste" should always be avoided – specific language like "90% post-consumer waste" or "curbside recyclable with mixed paper" is a far better option. 

With accusations of greenwashing flying around and cases of sustainability misrepresentation all too common, there's a lot of contradictory information out there. Being clear and concise with consumers makes a big difference.

CDU: Do you think consumers in the beauty sector are ready to prioritize sustainability over aesthetics in packaging design?​

SD​: I firmly believe that consumers in the beauty sector have an appetite for sustainable packaging. The data shows that consumers care about the environmental impact of product packaging on a broad level, and when it comes to cosmetic products, the figures remain solid.

Studies have shown that 75% of beauty sector consumers place some level of importance on the sustainability of cosmetic packaging (Statista​).

That said, it is also true that most individuals will prioritize other factors. Consumers are increasingly conscious of the quality of beauty products, the ingredients they include, and their cost.

It is important to emphasize that brands can adopt more sustainable packaging while achieving these goals. If they are clear on their priorities and those of their consumers, they can navigate their packaging decisions to strengthen their brand. Beautiful packaging showcasing a sustainable and innovative product is a huge win.