How the new Regulation (EU) 2025/40 transforms corrugated cardboard packaging management —and what your organization needs to do before 2028 to avoid regulatory surcharges and take advantage of REP eco-modulation bonuses.
Executive summary
- 20 PAP is the European code for corrugated cardboard, with a recycling rate of ~92% in the EU: the material with the lowest regulatory risk under the new framework.
- The PPWR Regulation (EU) 2025/40 replaces Directive 94/62/EC as of February 2025 and is directly applicable: it does not require national transposition.
- From August 12, 2028, harmonized labeling (pictogram + QR + class A/B/C) will be mandatory for all packaging placed on the EU market.
- Extended Producer Responsibility (EPR) fees will be eco-modulated: up to 30%-50% difference between Level A and Level C packaging according to national schemes under development.
- Immediate action: audit the packaging portfolio, identify references below the 70% recyclability threshold and replace them before 2030.
What the 20 PAP symbol is and why it matters
The code 20 PAP identifies corrugated cardboard within the European packaging material coding system established by Directive 94/62/EC. It functions as a core component of three critical processes: material traceability along the value chain, correct separation at the end-of-life stage, and environmental reporting to administrations and collective EPR systems.
For sustainability, packaging, and compliance managers, mastering this system—and understanding how it evolves under the new PPWR Regulation—is no longer a technical matter but a management variable with direct impact on three areas: regulatory compliance, regulatory costs via EPR, and ESG positioning with stakeholders and investors.
Composition and classification of the symbol
The 20 PAP symbol integrates three regulatory elements:
- Möbius loop: indicates material recyclability in accordance with ISO 14021.
- Numeric code "20": specific identifier for corrugated cardboard according to DIN 6120 and Decision 97/129/EC.
- Abbreviation "PAP": derived from the German Papier (paper), categorizes the material within the cellulose family.
Within the PAP family, the relevant codes for packaging are distributed as follows:
| Code | Material | Typical applications | EU recycling rate | Position vs. PPWR 2030 |
|---|---|---|---|---|
| PAP 20 | Corrugated cardboard | Secondary and tertiary packaging, shipping boxes, e-commerce, agri-food | ~92% | Exceeds target (90%) |
| PAP 21 | Solid board (paperboard) | Consumer packaging, premium packaging, retail | ~85% | Easily complies |
| PAP 22 | Paper | Bags, wraps, office paper | ~74% | Close to minimum threshold |
Current regulatory framework: Directive 94/62/EC
Under the Directive still in force for packaging placed on the market before the full application of the PPWR, the use of the 20 PAP symbol is voluntary at the European level. However, several Member States have gone further:
- Italy: mandatory since Legislative Decree 116/2020. Requires environmental labeling on all packaging marketed in Italy.
- Bulgaria: mandatory for packaging intended for the national market.
- France: the Triman logo is mandatory along with Info-tri (sorting instructions) according to the AGEC Law.
- Spain: Royal Decree 1055/2022 establishes marking and information requirements, progressively aligning with the PPWR.
Practical implication for exporters: any Spanish or Portuguese company shipping palletized products or boxes to Italy, France, or Bulgaria must include the 20 PAP on its corrugated cardboard packaging, regardless of the country of origin's regulations. Non-compliance can lead to administrative penalties and customs blockages.
The paradigm shift: PPWR Regulation (EU) 2025/40
The PPWR Regulation, published on January 22, 2025, and in force since February 11, 2025, replaces Directive 94/62/EC and rewrites the rules of the game for all actors in the packaging chain.
Five structural differences from the previous Directive
| Aspect | Directive 94/62/EC | PPWR Regulation (EU) 2025/40 |
|---|---|---|
| Legal nature | Directive (requires transposition) | Regulation (direct application in all 27 Member States) |
| Labeling | Voluntary, with national exceptions | Mandatory and harmonized across the EU |
| Recyclability criteria | Not defined at EU level | A/B/C system with quantified minimum thresholds |
| EPR fees | At the discretion of each Member State | Mandatory eco-modulation based on performance |
| Recycled content | No quantitative obligations | Minimum targets per category and year |
New harmonized labeling system (Art. 12 PPWR)
As of August 12, 2028, all packaging placed on the EU market must comply with the harmonized labeling system. This means progressively replacing current national symbols (Triman, Green Dot, Italian systems, etc.) with a single European identification.
Three mandatory components
- Unified pictograms: standardized designs approved by the European Commission through implementing acts, replacing national symbols.
- QR code or digital data carrier: link to information on composition, recyclability, and sorting instructions, aligned with the Digital Product Passport.
- Recyclability classification: visible indication of the A, B, or C level assigned to the packaging after Design-for-Recycling (DfR) assessment.
Recyclability classification system
The PPWR introduces a quantitative assessment of packaging recycling performance:
- Level A: recyclability ≥95%. Maximum efficiency. Reduced EPR fees.
- Level B: recyclability 80-94%. Standard compliance.
- Level C: recyclability 70-79%. Minimum threshold. Increased EPR fees.
- Below 70%: commercialization prohibited from 2030.
Critical prohibition dates
- January 1, 2030: prohibition of placing packaging with recyclability <70% on the market.
- January 1, 2038: prohibition of placing packaging with recyclability <80% on the market.
Well-designed corrugated cardboard (20 PAP)—without plastic coatings or contaminating adhesives, with recycling-compatible inks—consistently achieves Level A or B, positioning it as one of the lowest regulatory risk packaging options in the long term.
Economic impact: eco-modulation of EPR fees
The PPWR requires that Extended Producer Responsibility fees be modulated according to the actual recyclability of the packaging placed on the market. Although the final amount will depend on each national Collective Extended Responsibility System (SCRAP), published drafts point to significant differentials:
- Level A packaging: 10%-30% bonuses on the base fee.
- Level C packaging: 30%-100% penalties on the base fee.
- Packaging with certified recycled content: additional cumulative bonuses.
- Packaging with disruptive elements (labels, adhesives, incompatible inks): punitive surcharges.
For a manufacturer or distributor placing 1,000 tons of corrugated cardboard on the market annually, the difference between operating with Level A or Level C can range from €15,000 to €60,000 annually in EPR fees, according to simulations published by Ecoembes and equivalent European systems. This makes eco-design a margin variable, not just a compliance one.
Quantitative targets for paper and cardboard
The PPWR establishes specific goals for the cellulosic material category:
- 2030 recycling rate: 90% for paper and cardboard (corrugated cardboard already reaches ~92% in the EU).
- Minimum recycled content: to be defined in delegated acts, with initial thresholds expected for 2030 and five-year revisions.
- Reuse targets: applicable to certain B2B transport packaging formats (pallets, reusable boxes, pool systems).
- Packaging reduction: -5% per capita in 2030, -10% in 2035, -15% in 2040 compared to 2018.
Corrugated cardboard as a strategic material under the PPWR
Within the new regulatory framework, corrugated cardboard (20 PAP) offers competitive advantages that should be quantified when making corporate packaging decisions:
- High existing recycling rate: ~92% in the EU, already exceeding the 2030 target without the need for additional infrastructure investment.
- Consolidated collection infrastructure: mature network of blue bins, door-to-door collection, and treatment plants across the EU.
- Industrial recycling chain: sufficient installed capacity in European paper mills, with growing demand for recycled fiber.
- Biodegradability and renewable origin: natural alternative to growing restrictions on single-use plastics (SUPD) and multi-materials.
- Documentary traceability: FSC, PEFC certifications and third-party verifiable recycled content.
- Application in regulated sectors: especially relevant for food packaging, where food contact regulations converge with PPWR requirements.
For organizations with ESG objectives linked to packaging footprint—increasingly reported under CSRD and ESRS E5 standards on resource use and circular economy—well-specified corrugated cardboard radically simplifies reporting and the sustainability narrative for investors and rating agencies.
Compliance checklist for sustainability professionals
Short term (2025-2027)
- ☐ Audit the current packaging portfolio and identify all PAP 20, 21, and 22 packaging materials.
- ☐ Verify compliance in markets with mandatory labeling (Italy, Bulgaria, France, Spain).
- ☐ Evaluate the actual recyclability of current packaging according to PPWR criteria and harmonized standards under development (CEN/TC 261).
- ☐ Identify packaging at risk of falling below the 70% threshold by 2030 (multi-materials, plastic coatings, incompatible adhesives).
- ☐ Request technical data sheets with indicative A/B/C classification from packaging suppliers.
Medium term (2027-2028)
- ☐ Implement infrastructure for QR codes and data carriers on packaging.
- ☐ Adapt packaging designs to the harmonized labeling system and discontinue obsolete artwork.
- ☐ Establish traceability systems to report certified recycled content.
- ☐ Review framework agreements with packaging suppliers to include PPWR requirements (DfR clauses, recycled content, A/B/C classification).
- ☐ Integrate the EPR footprint into the total cost of ownership (TCO) calculation for packaging.
Long term (2028-2030)
- ☐ Ensure 100% of the portfolio complies with harmonized labeling.
- ☐ Optimize designs to consistently achieve Level A or B recyclability.
- ☐ Implement eco-design strategies to minimize EPR fees and maximize bonuses.
- ☐ Document and communicate the environmental performance of the packaging portfolio in CSRD/ESRS reports.
- ☐ Evaluate reuse systems (B2B, internal transport) where the business case justifies it.
Frequently asked questions about the 20 PAP symbol and the PPWR
Is the 20 PAP symbol mandatory in Spain in 2026?
At the European level, harmonized PPWR labeling is mandatory from August 12, 2028. In Spain, Royal Decree 1055/2022 already establishes marking and information requirements for packaging, progressively aligning with the new Regulation. For packaging intended for Italy, France, or Bulgaria, 20 PAP is mandatory from today.
What happens if my packaging does not reach 70% recyclability in 2030?
It cannot be legally marketed in the single European market. The prohibition is direct and does not require national transposition. Companies must have replaced or redesigned this packaging before January 1, 2030, to avoid disrupting their commercial operations.
How does the PPWR affect the fees I pay to Ecoembes?
Ecoembes and other collective EPR systems are obliged to apply eco-modulation: packaging with better recyclability will pay less, and worse packaging will pay more. The difference can reach 100% of the base fee between Level A and Level C, according to models in public consultation.
Does TeleCajas' corrugated cardboard comply with the PPWR?
Yes. Our standard corrugated cardboard is rated Level A or B for recyclability according to PPWR criteria, with a recycling rate of ≥92% and no disruptive elements. We provide technical data sheets and FSC/PEFC certifications to support corporate sustainability reporting.
Do I need to print the QR code on my boxes now?
It is not mandatory until August 12, 2028, but we recommend planning the redesign of artwork and the data infrastructure linked to the QR (Digital Product Passport) during 2026-2027 to avoid bottlenecks in 2028.
Conclusion: from compliance to strategic value
The 20 PAP symbol, although it will evolve into a more complete labeling system under the PPWR, will remain the key identifier for corrugated cardboard in packaging waste management. For sustainability, packaging, and compliance professionals, the transition represents both a compliance challenge and an opportunity to optimize the environmental footprint and regulatory cost of the portfolio.
Organizations that proactively adopt PPWR criteria—especially concerning recyclability and eco-design—will not only ensure regulatory compliance but also benefit from reduced EPR fees, improved perception by stakeholders and investors, and a solid ESG narrative in response to the new CSRD reporting requirements.
Do you need to ensure PPWR compliance for your corporate packaging?
At TeleCajas, we work with sustainability, packaging, and corporate purchasing managers to audit their packaging portfolio, identify at-risk references, and design corrugated cardboard solutions aligned with PPWR A/B/C criteria.
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