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EU PPWR: Paper Honeycomb Board Labeling and Printing Standards

In the PPWR compliance agenda of companies exporting to the European Union, the export carton and edge protectors usually take center stage. However, the paper honeycomb board, which is included in the same shipment, is defined as "packaging" under the PPWR (Packaging and Packaging Waste Regulation) and is subject to the exact same printing, marking, and traceability obligations as the export carton.Despite its light weight and simple appearance, the paper honeycomb board is a technical packaging component that falls under independent scrutiny in EU customs inspections. A honeycomb board lacking the required PPWR markings can solely constitute grounds for non-compliance, even if the export carton in the same shipment fully meets all requirements.This guide has been prepared for companies exporting to the European Union or preparing to enter this market, as well as packaging procurement managers, to fully understand at a technical level the PPWR requirements applicable to kraft paper-based brown paper honeycomb boards.What is PPWR and Why Does It Directly Affect Paper Honeycomb Boards?PPWR is a new-generation regulation that replaces the EU's former Packaging Directive 94/62/EC. Unlike a directive, a regulation does not wait to be transposed into the national legislation of member states; it applies directly and uniformly in all member countries the moment it enters into force. For every exporter entering the EU market from Turkey, this means a uniform and mandatory compliance obligation.The regulation aims to increase recycling rates, reduce packaging waste, and embed circular economy principles into every link of the supply chain. In this context, the paper honeycomb board is considered beyond a mere buffer, divider, or support element—it is treated as a technical packaging component that carries identification information, provides traceability, and contributes to the recycling system.Which Packaging Category Does Paper Honeycomb Board Fall Into?PPWR defines packaging according to functional categories:Primary packaging: Packaging in direct contact with the product.Secondary packaging: Grouping packaging that holds primary packages together.Tertiary / Transport packaging: Any packaging component that protects products from damage during handling and storage.Although paper honeycomb boards can fall into different tiers of this classification depending on their usage area, their most common functions in export shipments are:Pallet divider (layer pad): Placed between pallet layers to prevent products from damaging each other.Buffer and filler panel: Protects the product from impact by filling the voids inside the carton.Support and base board: Provides structural support at the pallet base or under the product.Edge and surface protection panel: Protects the edges and surfaces of large-area products.In all these usage forms, the paper honeycomb board falls under the scope of tertiary packaging. The definition in Article 3 of the PPWR clearly covers these functions.Practical outcome: The moment the paper honeycomb board enters EU customs, it is subject to the same regulatory inspection as the export carton.The Material Identity of Paper Honeycomb Board: 22 PAPThe paper honeycomb board discussed in this guide is a fully paper-based composite panel material consisting of a kraft paper-based honeycomb core and kraft paper surface linings (liners). Its brown color is the characteristic color of unbleached natural kraft paper.In the standard coding system established by the European Commission for packaging materials, this structure, which consists predominantly of paper-based material, is identified by the 22 PAP code.MaterialCodeAbbreviationApplication AreaCorrugated Board20PAPExport cartonSolid Board21PAPCardboard edge protectorKraft Paper / Paper Honeycomb Board22PAPPaper honeycomb board (standard)Technical Note: The material code of the paper honeycomb board may vary depending on the raw material composition. If board is used for the surface linings (liners), the code can also be applied as 21 PAP. Which code to use should be determined and documented by the manufacturer based on the raw material certificate. Arkas Packaging matches the raw material certificate with the code allocation for each production batch, providing proof to the exporter.PPWR Article 15 and Article 18: Core Compliance FrameworkThe two primary articles that directly regulate the printing and marking requirements on the paper honeycomb board are:Article 15 — Packaging Information: All information and symbols on the panel must remain legible, indelible, and verifiable throughout the component's lifecycle—from production and transport to storage and the recycling facility. This information must be resistant to physical conditions such as humidity, pressure, friction, and temperature changes in logistics processes.Article 18 — Traceability and Identification: The panel must bear a unique identification number that enables traceability and must include information identifying the manufacturer or importer. This article establishes an unbreakable link between the packaging component and the economic operator placing it on the market.When both articles are evaluated together, the resulting picture is clear: The paper honeycomb board must be designed during the production process regarding the permanence and accuracy of the information it carries.Physical Printing Rules: Material, Color, and FontThe physical standards for prints on the paper honeycomb board share the same parameters as other paper-based packaging components:ParameterMandatory StandardBase MaterialThe natural brown kraft paper surface of the panelPrint ColorBlackFontArialLegibilityIndelible throughout the entire lifecycleThe fundamental reason for these rules is practical: Black Arial print on a brown kraft surface provides maximum legibility for optical character recognition (OCR) systems in recycling facilities and manual barcode scanner readings. Different color or font combinations lead to scanning errors, thereby breaking the traceability chain.In this regard, the brown kraft surface of the paper honeycomb board has the same optical qualities as the natural brown background of the export carton; black print naturally meets standard requirements in terms of contrast and legibility.PPWR Article 15 and 18 Compliance: Print Durability and Avoiding LabelsArticles 15 and 18 of the PPWR mandate that the information on the packaging component remains legible throughout its entire lifecycle. At this point, a critical technical decision emerges: Using adhesive labels is a highly risky method for meeting the durability requirements of the PPWR.Due to its structural characteristics, the paper honeycomb board is subjected to unique conditions that make this risk even more prominent:Surface porosity: The natural porous structure of kraft paper leads to uneven penetration of the label adhesive, causing weak adhesion at the edges of the label.Pallet stretch film pressure: The stretch film applies uneven pressure to the panel surface. The honeycomb voids beneath the panel locally increase this pressure, curling or peeling the label off.Container and warehouse humidity: The moisture cycle in maritime transport, combined with the moisture-absorbing property of kraft paper, weakens the label adhesive; the label can lift off the surface.Static pressure and friction: The panel is exposed to friction caused by the weight and movement of the products within the pallet; these conditions can mechanically destroy the label.Cold chain conditions: In condensation environments, the bond strength of the label adhesive decreases, and the label surface blisters.During a customs inspection, any of these damages directly translates into a non-compliance report on the grounds of an "illegible marking."Arkas Packaging's Technical Approach:Instead of a label, direct printing is applied to the kraft paper surface of the panel using high-strength water-based black ink.Prints are tested using industrial protocols such as ASTM D5264 (Sutherland rub test) and ISO 18947 (abrasion resistance).The legibility of the print throughout all logistics processes is verified and documented through humidity chamber tests (95% humidity, 48 hours at 40°C), static load tests, and drop tests (ISTA 1A).For each batch of paper honeycomb boards, these tests are conducted in Arkas Packaging's own laboratory or at accredited external facilities, and a certificate of conformity is issued to the exporting company.Why Direct Print Instead of Labels?The surface structure of kraft paper and the internal structure of the paper honeycomb board make the use of labels physically problematic. Furthermore, the PPWR's principle of avoiding unnecessary chemicals adopts direct printing as the fundamental approach.Basic Rules and Why Labels Are ExcludedColor — Black Only: Colored labels or labels with pigmented inks disrupt the de-inking process during recycling. By using water-based black ink, Arkas Packaging ensures 100% recovery of the paper pulp.Font — Arial or Sans-serif: Even if the correct font is used on the label, the font requirement is considered violated if the label detaches from the kraft surface. In direct printing, the font is an inseparable part of the material.Adhesive Contamination: Acrylic or hot-melt adhesives used in labels cause contamination in the recycling pool. PPWR Annex II (Recyclability Criteria) restricts such adhesives.Pressure distribution of the honeycomb structure: The label affixed to the panel is suspended in the air over the void areas of the honeycomb cells; adhesion only occurs at the top points of the cell walls. This can effectively reduce the surface adhesion area of the label down to 30-40%.Arkas Packaging's Testing and Approval ProcessesRub Test: Using a Sutherland rub tester with 2 kg pressure, print loss must be ≤ 5% after 10 double strokes.Scotch Tape Test (ASTM D3359-Method B): The print's adhesion resistance to the surface must be at a 4B or 5B level.Damp Rub Test: There must be no bleeding or smearing of the print in condensation environments.UV Fading Test (ISO 12040): Color change ΔE ≤ 1.5 after 24 hours under a Xenon lamp.Application Note: In flexo or digital printing technologies, ink penetration and density must be adjusted according to the absorbency characteristics of the paper honeycomb board's kraft paper surface. Ink viscosity and printing speed are production variables that need to be calibrated according to surface roughness and porosity parameters. This falls under the technical responsibility of the packaging manufacturer.Outer (Top) Surface Printing RequirementsThe outward-facing surface of the paper honeycomb board—the kraft paper surface that is visibly positioned within the shipment or on the pallet—is the primary area where logistics and regulatory identity are carried. Under the PPWR, it is mandatory to have the following elements fully present on this surface:1. Exporter / Manufacturer Company Identification DetailsThe company's full commercial address (at the street, city, and country level).Website address and/or other digital communication channels.(This information is mandatory so that EU customs authorities and market surveillance bodies can quickly identify the economic operator placing the product on the market.)2. ISO 7000 Series SymbolsEU legislation mandates the use of international graphical symbols to identify the entity placing the packaging component on the market:ISO 7000-3082 Symbol: Used by the company that actually manufactures the paper honeycomb board (Manufacturer).ISO 7000-3725 Symbol: Used by the company that introduces the paper honeycomb board to the EU market but does not manufacture it itself (Importer).Every exporter must use only one of these two symbols, depending on their role in the supply chain. Using both together or selecting the wrong symbol constitutes direct grounds for non-compliance.3. Unique Packaging IDIt is mandatory for the honeycomb boards belonging to each production batch to bear a system-registered unique Packaging ID. This identification number links the panel to the production batch, material certificate, and traceability record.Production Date: Stating the week number and year format (e.g., W18/2025) is optional; however, it provides strong practical convenience in terms of supply chain management and potential recall procedures.Back / Bottom Surface (Recycling) Printing RequirementsThe back or bottom surface of the paper honeycomb board that comes into contact with the product or pallet surface is the mandatory area reserved for recycling information. All symbols on this surface must be visible and legible from the outside, not when the panel is within the shipment, but after the panel is separated from the product or pallet—that is, when it enters the waste management process.This placement rule is operationally mandatory so that automated sorting systems in recycling facilities can direct the panel to the correct stream. The elements mandatory on the back/bottom surface are listed below:1. Recycling LogoThe standard recycling pictogram indicating that the packaging component is a recyclable material must be located in this area. With its 100% paper-based structure, the paper honeycomb board is a material with high recovery value in the recycling system; visually indicating this characteristic with a logo is mandatory from a regulatory standpoint and a functional requirement for the circular economy.2. RESY Symbol and RESY Identification NumberRESY is the trademarked symbol of the recycling and take-back system operated for transport packaging in Europe. The system has become mandatory in many EU member states, especially Germany.The RESY logo must be visually present on the back/bottom surface of the panel.In addition, the RESY member/identification number belonging to the packaging manufacturer that produced the panel must be included in text format.This number proves that the packaging manufacturer is registered with the RESY system; it relieves the exporting company from the responsibility of independently verifying whether the manufacturer has fulfilled the system registration obligation. Arkas Packaging's RESY identification number is printed as standard on the back/bottom surface of every batch of paper honeycomb boards produced.3. "22 PAP" Material Identification CodeIn the standard coding system established by the European Commission, the kraft paper-based paper honeycomb board is defined by the 22 PAP code.Both the numeric code (22) and the abbreviation (PAP) must be written together on the back/bottom surface.This code is mandatory so that recycling facilities can automatically direct the material to the correct paper recycling stream.MaterialCodeAbbreviationCorrugated Board20PAPSolid Board21PAPKraft Paper / Paper Honeycomb Board22PAP4. Triman LogoTriman is a symbol system originating in France that has now become the standard for packaging recycling information in multiple EU member states. The use of the Triman logo is mandatory for all transport packaging components, including paper honeycomb boards.Triman warns the consumer and the waste management operator that the packaging component is recyclable. It is the visual component of the circular economy infrastructure aimed at reducing emissions caused by incorrect waste sorting. The 100% paper-based structure of the paper honeycomb board directly aligns with the "single material, full recycling" principle targeted by the Triman system.Customs and Market Risks of Non-ComplianceThe customs and market surveillance authorities of EU Member States have implemented systematic inspections covering all transport packaging components, including paper honeycomb boards, as of 2024. The practical risks encountered are as follows:Shipment Detention: Honeycomb boards bearing incomplete or illegible print information constitute sufficient grounds alone for the entire shipment to be detained at customs.Product Return: The detection of an incorrect symbol, missing code, or illegible marking can lead to the entire batch being returned to the exporter.Administrative Fines: Placing products on the market with non-compliant packaging components is directly subject to sanctions under member state legislation.Brand Reputation Damage: Large-scale buyers, particularly in Germany, France, and the Netherlands, are now including packaging components within the standard scope of supplier qualification audits. A non-compliance originating from paper honeycomb boards directly and negatively affects the respective exporter's supplier track record.Paper Honeycomb Board PPWR Compliance with Arkas Packaging: Technical Supply SolutionsArkas Packaging, one of Turkey's established industrial packaging manufacturers, has created a comprehensive compliance framework encompassing paper honeycomb board production with the entry into force of the PPWR.Technical standards offered by Arkas Packaging in the paper honeycomb board production process:PPWR Article 15 and 18 Compliant Print Design: All information areas are technically verified prior to production according to the permanence, legibility, and placement standards envisioned by the regulation. Ink viscosity and printing parameters suitable for the unique surface structure of kraft paper are calibrated on the production line.22 PAP Material Code Application: The code suitable for the kraft paper raw material structure is applied as a standard on the production line, matched with the material certificate for every batch.ISO 7000 Series Symbol Integration: The correct symbol is included in the print template according to the customer's role in the supply chain.RESY Membership Infrastructure: Arkas Packaging's RESY identification number is printed as standard on the back/bottom surface of every batch of paper honeycomb boards produced, securing the exporting company in terms of system compliance.22 PAP, Triman, and Recycling Logo Printing: Applied on the production line in accordance with back/bottom surface placement rules.Packaging ID Allocation: A unique identification number is generated for each production batch and matched with the exporter's document set.Durability Test Protocol: Print permanence is documented for each batch through the Sutherland rub test, Scotch tape test, humidity chamber test, and UV fading test, and a certificate of conformity is issued.The integration of these steps into the production process by the packaging supplier significantly reduces the manual checking burden on exporters before each shipment and systematically eliminates the risk of non-compliance.Summary: Paper Honeycomb Board PPWR Compliance ChecklistThe following table is the core audit list that every exporter and packaging procurement manager can use during the production approval process:AreaMandatory ElementStandard / SourcePhysical PrintBlack ink, Arial font, brown kraft backgroundPPWR Article 15Outer / Top SurfaceCompany full address + websitePPWR Article 18Outer / Top SurfaceISO 7000-3082 or ISO 7000-3725 symbolISO 7000 SeriesOuter / Top SurfaceUnique Packaging IDPPWR Article 18Outer / Top SurfaceProduction date (W/Year)OptionalBack / Bottom SurfaceRecycling logoPPWR Article 15Back / Bottom SurfaceRESY symbol + manufacturer's RESY numberRESY System RulesBack / Bottom Surface22 PAP codeEU Packaging CodingBack / Bottom SurfaceTriman logoTriman SystemGeneralAll prints legible throughout the panel's lifespanPPWR Article 15Frequently Asked Questions (FAQ)1. Paper honeycomb board is an auxiliary material placed inside the export carton; do PPWR obligations really apply to this component as well?Yes, they apply without exception. Article 3 of the PPWR defines any material that protects the product from damage and contamination and facilitates the storage and transport process as "packaging." The paper honeycomb board directly meets this definition. The regulation is based not on whether a packaging component is "auxiliary" or "minor," but on whether it serves a packaging function. EU customs inspection officers closely monitor this distinction in practice.2. Should the material code for the paper honeycomb board be 22 PAP, or can a different code be used?The material code is determined by the raw material composition of the panel. For a paper honeycomb board where both the core and the surface linings are made of kraft paper, the 22 PAP code is appropriate. However, if board is predominantly used in the surface linings (liners), the code can be evaluated as 21 PAP. This distinction must be based on the manufacturer's raw material certificate and documented for every batch. The use of an incorrect code leads to the material being directed to the wrong stream in the recycling facility and causes regulatory non-compliance. Arkas Packaging eliminates this risk at its source by matching the raw material certificate with the print code for every production batch.3. Should the exporter obtain the RESY number, or is this the responsibility of the packaging manufacturer?The RESY identification number is a systemic registration number belonging to the company that manufactures the packaging component. Therefore, obtaining and printing this number is directly the responsibility of the packaging manufacturer. What the exporting company needs to do is to verify whether the packaging manufacturer they supply from is registered with the RESY system and to confirm in the supplier contract that this number is applied as standard to the back/bottom surface on the production line.

EU PPWR Cardboard Corner Protector Labeling Guide

A Guide to Cardboard Edge Protectors and PPWR Compliance in Exports to the European UnionAuthor: Arkas Packaging Technical TeamCategory: Regulation & ComplianceUpdated: 05/2026The majority of companies exporting to the European Union tend to limit their PPWR compliance agenda solely to the export carton. While this approach is operationally understandable, it creates a serious regulatory gap. The cardboard edge protector, positioned inside or outside the shipping package, is defined as "packaging" under the EU's PPWR (Packaging and Packaging Waste Regulation). Therefore, it is subject to the exact same printing, marking, and traceability obligations as the export carton itself.The fact that exporters have not fully grasped this reality sets the stage for surprise non-compliance findings during customs inspections. The inspecting officer has the authority to scrutinize the edge protector on the pallet using the same procedure applied to the PPWR prints on the export carton.This guide has been prepared for companies exporting to the European Union or preparing to enter this market, as well as packaging procurement managers, to fully understand at a technical level the PPWR requirements applicable to solid board-based cardboard edge protectors.What is PPWR and Why Does It Directly Affect Cardboard Edge Protectors?PPWR is a new-generation regulation that replaces the EU's former Packaging Directive 94/62/EC. Unlike a directive, a regulation does not wait to be transposed into the national legislation of member states; it applies directly and uniformly in all member countries the moment it enters into force. For every exporter entering the EU market from Turkey, this means a uniform and mandatory compliance obligation.The regulation aims to increase recycling rates, reduce packaging waste, and embed circular economy principles into every link of the supply chain.Which Packaging Category Do Cardboard Edge Protectors Fall Into?PPWR defines packaging according to functional categories:Primary packaging: Packaging in direct contact with the product.Secondary packaging: Grouping packaging that holds primary packages together.Tertiary / Transport packaging: Any packaging component that protects products from damage during handling and storage.In this classification, the cardboard edge protector falls under the tertiary packaging category. It is a packaging component that protects the corners and edges of the product stack on the pallet against impact, compression, and deformation; it is separated from the product once the transport process is complete to be subjected to recycling. The definition of "packaging" under Article 3 of the PPWR clearly covers this function.Practical outcome: The moment the cardboard edge protector enters EU customs, it is subject to the same regulatory inspection as the export carton.The Material Identity of Cardboard Edge Protectors: 21 PAPThe cardboard edge protector discussed in this guide is produced from a material known as solid board, or in industrial terminology, chipboard or recycled paperboard. In the standard coding system established by the European Commission for packaging materials, this material is identified by the code 21 PAP.MaterialCodeAbbreviationApplication AreaCorrugated Board20PAPExport cartonSolid Board21PAPCardboard edge protector (standard)Paperboard22PAPThin cardboard-based packagingThe vast majority of cardboard edge protectors on the market are solid board-based. Documenting this alignment between the edge protector's raw material structure and the print code with a material certificate is of critical importance for the exporter to meet the burden of proof during customs inspections.PPWR Article 15 and Article 18: Core Compliance FrameworkThe two primary articles that directly regulate the printing and marking requirements on cardboard edge protectors are:Article 15 — Packaging Information: All information and symbols on the edge protector must remain legible, indelible, and verifiable throughout the component's lifecycle—from production and transport to storage and the recycling facility. This information must be resistant to physical conditions such as humidity, pressure, friction, and temperature changes in logistics processes.Article 18 — Traceability and Identification: The edge protector must bear a unique identification number that enables traceability and must include information identifying the manufacturer or importer. This article establishes an unbreakable link between the packaging component and the economic operator placing it on the market.When both articles are evaluated together, the resulting picture is clear: The cardboard edge protector must be designed during the production process regarding the permanence and accuracy of the information it carries.Physical Printing Rules: Material, Color, and FontThe physical standards for prints on cardboard edge protectors share the same parameters as the corrugated export carton:ParameterMandatory StandardBase MaterialNatural gray / beige surface of the edge protector (solid board)Print ColorBlackFontArialLegibilityIndelible throughout the entire lifecycleThe fundamental reason for these rules is practical: Black Arial print on a natural background provides maximum legibility for optical character recognition (OCR) systems in recycling facilities and manual barcode scanner readings. Different color or font combinations lead to scanning errors, thereby breaking the traceability chain.PPWR Article 15 and 18 Compliance: Print Durability and Avoiding LabelsArticles 15 and 18 of the PPWR mandate that the information on the packaging component remains legible throughout its entire lifecycle. At this point, a critical technical decision emerges: Using adhesive labels is a highly risky method for meeting the durability requirements of the PPWR.The usage conditions of cardboard edge protectors make this risk particularly evident. The edge protector is subjected to the following loads during the shipment process:Pallet stretch film (stretch wrap) pressure: The friction between the film and the edge protector pushes, curls, or peels off adhesive labels.Container and warehouse humidity: The moisture cycle in maritime transport lifts the label from underneath, destroying legibility.Static stacking load: The pressure from the upper layers of the pallet can mechanically deform the label surface.Cold chain conditions: In condensation environments, the adhesive properties on the label deteriorate, and the label surface blisters.During a customs inspection, any of these damages directly translates into a non-compliance report on the grounds of an "illegible marking."Arkas Packaging's Technical Approach:Instead of a label, direct printing is applied to the solid board surface of the edge protector using high-strength water-based black ink.Prints are tested using industrial protocols such as ASTM D5264 (Sutherland rub test) and ISO 18947 (abrasion resistance).The legibility of the print throughout all logistics processes is verified and documented through humidity chamber tests (95% humidity, 48 hours at 40°C), static load tests, and drop tests (ISTA 1A).For each batch of cardboard edge protectors, these tests are conducted in Arkas Packaging's own laboratory or at accredited external facilities, and a certificate of conformity is issued to the exporting company.Why Direct Print Instead of Labels?The surface structure and absorbency characteristics of solid board make label usage physically problematic. Furthermore, the PPWR's principle of avoiding unnecessary chemicals adopts direct printing as the fundamental approach.Basic Rules and Why Labels Are ExcludedColor — Black Only: Colored labels or labels with pigmented inks disrupt the de-inking process during recycling. By using water-based black ink, Arkas Packaging ensures 100% recovery of the paper pulp.Font — Arial or Sans-serif: Even if the correct font is used on the label, the font requirement is considered violated if the label detaches from the solid board surface. In direct printing, the font is an inseparable part of the material.Adhesive Contamination: Acrylic or hot-melt adhesives used in labels cause contamination in the recycling pool. PPWR Annex II (Recyclability Criteria) restricts such adhesives.Arkas Packaging's Testing and Approval ProcessesRub Test: Using a Sutherland rub tester with 2 kg pressure, print loss must be ≤ 5% after 10 double strokes.Scotch Tape Test (ASTM D3359-Method B): The print's adhesion resistance to the surface must be at a 4B or 5B level.Damp Rub Test: There must be no bleeding or smearing of the print in condensation environments.UV Fading Test (ISO 12040): Color change ΔE ≤ 1.5 after 24 hours under a Xenon lamp.Application Note: In flexo or digital printing technologies, ink penetration and density must meet standard requirements following humidity and compression tests. This falls under the technical responsibility of the packaging manufacturer.Outer (Side) Surface Printing RequirementsThe outward-facing surface of the edge protector is the primary area where logistics and regulatory identity are carried. Under the PPWR, it is mandatory to have the following elements fully present on this surface:1. Exporter / Manufacturer Company Identification DetailsThe company's full commercial address (at the street, city, and country level).Website address and/or other digital communication channels.(This information is mandatory so that EU customs authorities and market surveillance bodies can quickly identify the economic operator placing the product on the market.)2. ISO 7000 Series SymbolsEU legislation mandates the use of international graphical symbols to identify the entity placing the packaging component on the market:ISO 7000-3082 Symbol: Used by the company that actually manufactures the edge protector (Manufacturer).ISO 7000-3725 Symbol: Used by the company that introduces the edge protector to the EU market but does not manufacture it itself (Importer).Every exporter must use only one of these two symbols, depending on their role in the supply chain. Using both together or selecting the wrong symbol constitutes direct grounds for non-compliance.3. Unique Packaging IDIt is mandatory for the edge protectors belonging to each production batch to bear a system-registered unique Packaging ID. This identification number links the edge protector to the production batch, material certificate, and traceability record.Production Date: Stating the week number and year format (e.g., W22/2025) is optional; however, it provides strong practical convenience in terms of supply chain management and recall procedures.Inner Surface (Recycling) Printing RequirementsThe inner surface of the cardboard edge protector that comes into contact with the product or pallet surface is the mandatory area reserved for recycling information. All symbols on this surface must be visible and legible from the outside, not when the edge protector is mounted on the product, but after the edge protector is separated from the product—that is, when it enters the waste management process.Although this placement rule seems like a technical detail, it serves a critical function for the correct operation of automated sorting systems in recycling facilities. The elements mandatory on the inner surface are listed below:1. Recycling LogoThe standard recycling pictogram indicating that the packaging component is a recyclable material must be located in this area.2. RESY Symbol and RESY Identification NumberRESY is the trademarked symbol of the recycling and take-back system operated for transport packaging in Europe. The system has become mandatory in many EU member states, especially Germany.The RESY logo must be visually present on the inner surface of the edge protector.In addition, the RESY member/identification number belonging to the packaging manufacturer that produced the edge protector must be included in text format.This number proves that the packaging manufacturer is registered with the RESY system; it relieves the exporting company from the responsibility of independently verifying whether the manufacturer has fulfilled the system registration obligation. Arkas Packaging's RESY identification number is printed as standard on the inner surface of every batch of edge protectors produced.3. "21 PAP" Material Identification CodeIn the standard coding system determined by the European Commission for packaging materials, the solid board-based cardboard edge protector is defined by the code 21 PAP.Both the numeric code (21) and the abbreviation (PAP) must be written together on the inner surface.This code is mandatory so that recycling facilities can automatically direct the material to the correct stream.4. Triman LogoTriman is a symbol system originating in France that has now become the standard for packaging recycling information in multiple EU member states. The use of the Triman logo is mandatory for all transport packaging components, including cardboard edge protectors.Triman warns the consumer and the waste management operator that the packaging component is recyclable. It is the visual component of the circular economy infrastructure aimed at reducing emissions caused by incorrect waste sorting.Customs and Market Risks of Non-ComplianceThe customs and market surveillance authorities of EU Member States have implemented systematic inspections covering packaging components as of 2024. The practical risks encountered due to non-compliance originating from cardboard edge protectors are as follows:Shipment Detention: Edge protectors bearing incomplete or illegible print information constitute sufficient grounds alone for the entire shipment to be detained at customs.Product Return: The detection of an incorrect symbol, missing code, or illegible marking can lead to the entire batch being returned to the exporter.Administrative Fines: Placing products on the market with non-compliant packaging components is directly subject to sanctions under member state legislation.Brand Reputation Damage: Large-scale buyers, particularly in Germany, France, and the Netherlands, are now including packaging components within the standard scope of supplier qualification audits.Cardboard Edge Protector PPWR Compliance with Arkas Packaging: Technical Supply SolutionsArkas Packaging, one of Turkey's established industrial packaging manufacturers, has created a comprehensive compliance framework encompassing cardboard edge protector production with the entry into force of the PPWR.Technical standards offered by Arkas Packaging in the cardboard edge protector production process:PPWR Article 15 and 18 Compliant Print Design: All information areas are technically verified prior to production according to the permanence, legibility, and placement standards envisioned by the regulation.21 PAP Material Code Application: The code suitable for the solid board raw material structure is applied as a standard on the production line; it is matched with the material certificate for every batch.ISO 7000 Series Symbol Integration: The correct symbol is included in the print template according to the customer's role in the supply chain.RESY Membership Infrastructure: Arkas Packaging's RESY identification number is printed as standard on the inner surface of every batch produced, securing the exporting company in terms of system compliance.21 PAP, Triman, and Recycling Logo Printing: Applied on the production line in accordance with inner surface placement rules.Packaging ID Allocation: A unique identification number is generated for each production batch and matched with the exporter's document set.Durability Test Protocol: Print permanence is documented for each batch through the Sutherland rub test, Scotch tape test, humidity chamber test, and UV fading test, and a certificate of conformity is issued.The integration of these steps into the production process by the packaging supplier significantly reduces the manual checking burden on exporters before each shipment and systematically eliminates the risk of non-compliance.Summary: Cardboard Edge Protector PPWR Compliance ChecklistThe following table is the core audit list that every exporter and packaging procurement manager can use during the production approval process:AreaMandatory ElementStandard / SourcePhysical PrintBlack ink, Arial font, natural backgroundPPWR Article 15Outer SurfaceCompany full address + websitePPWR Article 18Outer SurfaceISO 7000-3082 or ISO 7000-3725 symbolISO 7000 SeriesOuter SurfaceUnique Packaging IDPPWR Article 18Outer SurfaceProduction date (W/Year)OptionalInner / Recycling SurfaceRecycling logoPPWR Article 15Inner / Recycling SurfaceRESY symbol + manufacturer's RESY numberRESY System RulesInner / Recycling Surface21 PAP codeEU Packaging CodingInner / Recycling SurfaceTriman logoTriman SystemGeneralAll prints legible throughout the edge protector's lifespanPPWR Article 15Frequently Asked Questions (FAQ)1. Are PPWR printing obligations for cardboard edge protectors valid across the entire EU market, or do they only apply to those exporting to specific countries?PPWR is an EU regulation; it is directly based on EU law, not on the national legislation of any member state. Therefore, it applies equally to exports made to Germany, France, Italy, Poland, or all other 27 member state markets. Exporting to a specific country does not provide an exemption from the legislation of other member states; the edge protector falls under the scope of the regulation the moment it enters the EU customs union.2. What should we do if our current stock of edge protectors does not have PPWR-compliant printing?While it is theoretically possible to partially comply edge protectors currently in stock that do not meet PPWR requirements by adding labels, these additions must meet the "legibility throughout the entire lifecycle" standard mandated by PPWR Article 15. Retroactively applied adhesive labels will highly likely fail to meet this standard under stretch film pressure, humidity, and mechanical load conditions. The safest route is not to use the non-compliant stock for export purposes and to replace it with a new batch procured from PPWR-compliant production.3. Should the exporter obtain the RESY number, or is this the responsibility of the packaging manufacturer?The RESY identification number is a systemic registration number belonging to the company that manufactures the packaging component. Therefore, obtaining and printing this number is directly the responsibility of the packaging manufacturer. What the exporting company needs to do is to verify whether the packaging manufacturer they supply from is registered with the RESY system and to confirm in the supplier contract that this number is applied as standard to the inner surface on the production line.

EU PPWR-Compliant Corrugated Export Cartons

Author: Arkas Ambalaj Technical Team | Category: Regulation & Compliance | Updated: 05/2026Every Turkish company exporting goods to the European Union — or preparing to enter that market — is now accountable not only for the quality of its products, but for the technical identity carried by the export carton that delivers them. The obligations introduced under the EU's PPWR (Packaging and Packaging Waste Regulation) have fundamentally redefined the printing and labelling requirements for corrugated cardboard export cartons. A shipment that fails to meet these requirements can trigger consequences ranging from customs detention and product return to administrative fines and permanent market exclusion.This guide has been prepared to help exporters and packaging procurement managers fully understand the technical requirements of the regulation.What Is PPWR and Why Does It Directly Concern Exporters?PPWR is the next-generation EU regulation that replaces the former Packaging Directive 94/62/EC. Unlike a directive, a regulation does not require transposition into national law by member states; it applies directly across all member countries from the moment it enters into force. For every exporter sending goods from Turkey into the EU market, this means a uniform and strictly enforced compliance obligation.The regulation aims to increase recycling rates, reduce packaging waste, and embed circular economy principles throughout every link in the supply chain. In this context, the corrugated cardboard export carton is treated not merely as a transport vessel, but as a technical component that carries identity information, enables traceability, and contributes to the recycling system.PPWR Articles 15 and 18: The Core Compliance FrameworkTwo critical articles directly govern the printing requirements for corrugated cardboard export cartons: Article 15 and Article 18.Article 15 — Packaging Information: All information on packaging must remain legible, indelible, and verifiable throughout the packaging's entire service life. This information must be resistant to physical conditions encountered during logistics processes — including moisture, pressure, abrasion, and temperature variation.Article 18 — Traceability and Identity: Packaging must be identified with a registered unique identification number and must contain information that allows the manufacturer or importer to be established. This article makes the link between packaging and the party responsible for placing it on the market unbreakable.Taken together, both articles point to a clear conclusion: export cartons must be engineered at the production stage with regard to the permanence and accuracy of the information they carry.Physical Printing Rules: Material, Colour, and TypefaceThe physical standards governing printing on corrugated cardboard export cartons leave no room for arbitrary preference.ParameterMandatory StandardSubstrateNatural brown surface of corrugated cardboardPrint ColourBlackTypefaceArialLegibilityIndelible throughout the entire service lifeThe rationale behind these rules is practical: black Arial print on a brown substrate delivers maximum readability for the optical character recognition (OCR) systems used in recycling facilities, as well as for manual barcode scanner operations. Alternative colour or typeface combinations introduce scanning errors that break the traceability chain.PPWR Articles 15 and 18 Compliance: Print Durability and the Case Against LabelsArticles 15 and 18 of PPWR require that information on packaging remains legible throughout its entire lifecycle. This raises a critical technical decision: adhesive label application is a high-risk method for meeting PPWR's durability requirements. Labels are susceptible to moisture-induced bubbling in cold-chain storage, delamination or tearing under mechanical friction, and fading upon UV exposure. Any of these failure modes constitutes a direct non-conformance finding at customs on grounds of "illegible marking."Arkas Ambalaj's technical approach:Direct print is applied to the cardboard surface using high-durability water-based ink, eliminating the label entirely.Prints are tested against industrial protocols including ASTM D5264 (Sutherland rub resistance) and ISO 18947 (abrasion resistance).Humidity chamber testing (95% RH, 40 °C for 48 hours) and drop testing (ISTA 1A) verify print legibility through all stages of the logistics process.In summary: PPWR's legibility requirement turns the label into a risk factor. Arkas Ambalaj eliminates that risk through a fully integrated material–ink–print process that maintains print integrity at every stage of the supply chain.Corrugated Cardboard Physical Printing Rules: Why Direct Print, Not Labels?The surface structure (fluting) and absorbency characteristics of corrugated cardboard also make label application problematic on purely physical grounds. PPWR's principle of avoiding unnecessary chemical inputs further reinforces direct printing as the standard approach.Core Rules (and Why Labels Are Excluded)Colour — black only. Coloured labels or pigment-ink labels disrupt the de-inking process during recycling. Arkas Ambalaj uses water-based black ink to ensure 100% recovery of the paper pulp.Typeface — Arial or sans-serif. Even if a label carries the correct font, any separation of the label from the board constitutes a violation of the typeface requirement. With direct print, the typeface is an inseparable part of the substrate.Adhesive contamination. Acrylic or hot-melt adhesives used on labels introduce contamination into the recycling pulp bath. PPWR Annex II (Recyclability Criteria) restricts such adhesives.Arkas Ambalaj Testing and Approval ProtocolsRub test: Using a Sutherland rub tester at 2 kg pressure, print loss after 10 double rubs must be ≤ 5%.Tape adhesion test (ASTM D3359, Method B): Print adhesion to the substrate must be rated 4B or 5B.Wet rub test: No smearing or transfer may occur in condensation environments (e.g., cold-chain logistics).UV fade test (ISO 12040): Colour change after 24 hours under a Xenon lamp must be ΔE ≤ 1.5.Arkas Ambalaj carries out all of these tests in its own laboratory or at accredited third-party facilities, issuing a conformity certificate for every batch of export cartons produced. This enables exporting companies to document full PPWR compliance to customs authorities at any point of inspection.Application Note: For flexographic or digital printing technologies, ink penetration depth and ink density must meet the required standards following moisture and compression testing. This falls within the technical responsibility of the packaging manufacturer.External (Side) Surface Printing RequirementsThe side panels of the carton are the primary surface carrying its logistical and regulatory identity. Under PPWR, the following elements must be present on this surface without exception:1. Exporter / Manufacturer Company IdentityThe company's full registered address (street, city, country)Website address and/or other digital contact channelsThis information is required so that EU customs authorities and market surveillance bodies can rapidly identify the party responsible for placing the goods on the market.2. ISO 7000 Series SymbolsEU legislation mandates the use of internationally standardised graphical symbols to identify the party responsible for the packaging:ISO 7000-3082 Symbol: Used by the company that physically manufactures the packaging (Manufacturer).ISO 7000-3725 Symbol: Used by the company that places the product on the EU market but does not manufacture the packaging itself (Importer).Each exporter must use only one of these two symbols, determined by its role in the supply chain. Using both simultaneously, or selecting the wrong symbol, constitutes a ground for non-conformance.3. Unique Packaging IDEvery carton in a production batch must carry a registered unique Packaging ID. This identification number links the packaging to its production batch, material certificate, and traceability record.Production Date: Designation in week-number and year format (e.g., W14/2025) is optional, but provides strong practical value for supply chain management purposes.Bottom Surface (Recycling) Printing RequirementsThe bottom flaps of the corrugated export carton are the designated mandatory area for recycling information. All symbols placed on this surface must be externally visible once the carton is sealed — that is, once the bottom flaps are interlocked. While this placement rule may appear to be a minor technical detail, it is operationally critical for the correct functioning of automated sorting systems in recycling facilities.The elements that must appear on the bottom surface are listed below:1. Recycling LogoThe standard recycling pictogram indicating that the packaging is made from a recyclable material must appear in this area.2. RESY Symbol and RESY Identification NumberRESY is the trademarked symbol of the return and recycling scheme operated for transport packaging in Europe. The system is mandatory in Germany and has been adopted as a requirement in several other EU member states.The RESY logo must appear visually on the bottom surface of the carton.In addition, the RESY member/identification number of the packaging manufacturer must appear in text form.This number confirms that the packaging manufacturer is registered with the RESY system, relieving the exporting company of the burden of independently verifying the manufacturer's registration compliance.3. "20 PAP" Material Identification CodeUnder the standard coding system established by the European Commission for packaging materials, corrugated cardboard is identified by the code 20 PAP.Both the numerical code (20) and the abbreviation (PAP) must appear together on the bottom surface.This code enables recycling facilities to automatically direct the material to the correct processing stream.MaterialCodeAbbreviationCorrugated Cardboard20PAPFlat Cardboard21PAPPaperboard / Carton22PAP4. Triman LogoTriman originated in France and has since become a standard symbol for packaging recyclability information in multiple EU member states. Use of the Triman logo is mandatory for corrugated cardboard export cartons.Triman informs both the end consumer and waste management operators that the packaging is recyclable in nature; it is the visual component of the circular economy infrastructure designed to reduce misclassification emissions in waste sorting.Non-Compliance: Customs and Market RisksCustoms authorities and market surveillance bodies across EU member states have been conducting systematic audits of packaging compliance since 2024. The practical risks exporters face include:Shipment detention: Cartons carrying incomplete or incorrect marking information may be held at customs.Product return: Incorrect symbol or code usage can result in the entire consignment being returned to the exporter.Administrative fines: Placing products on the market in non-compliant packaging is subject to direct sanctions under member state legislation.Brand reputation damage: For exporters working with retail buyers, supplier qualification may be called into question.PPWR Compliance with Arkas Ambalaj: Technical Procurement SolutionsArkas Ambalaj, one of Turkey's established industrial packaging manufacturers, has developed an integrated compliance framework for exporters since PPWR came into force.Technical standards delivered by Arkas Ambalaj within its export carton production process:PPWR Articles 15 and 18-compliant print design: All information fields are technically verified prior to production against the regulation's requirements for permanence, legibility, and placement.ISO 7000 series symbol integration: The correct symbol is incorporated into the print template based on the customer's role in the supply chain.RESY membership infrastructure: Arkas Ambalaj's RESY identification number is printed as a standard item on the bottom surface of every carton produced in each batch, providing the exporter with systemic compliance assurance.20 PAP, Triman, and recycling logo printing: Applied on the production line in conformity with bottom flap placement requirements.Packaging ID assignment: A unique identification number is generated for each production batch and matched to the exporter's documentation set.When a packaging supplier integrates these steps into the production process, exporters are substantially relieved of the manual verification burden before every shipment, and the risk of non-conformance is eliminated on a systematic basis.Summary: PPWR Export Carton Compliance ChecklistThe table below is a core compliance audit checklist that every exporter can use during the production approval process:Surface / AreaMandatory ElementStandard / SourcePhysical PrintBlack ink, Arial typeface, brown substratePPWR Article 15Side SurfaceFull company address + websitePPWR Article 18Side SurfaceISO 7000-3082 or ISO 7000-3725 symbolISO 7000 SeriesSide SurfaceUnique Packaging IDPPWR Article 18Side SurfaceProduction date (W/Year)OptionalBottom SurfaceRecycling logoPPWR Article 15Bottom SurfaceRESY symbol + manufacturer RESY numberRESY System RulesBottom Surface20 PAP codeEU Packaging CodingBottom SurfaceTriman logoTriman SystemGeneralAll print legible throughout carton service lifePPWR Article 15Frequently Asked Questions (FAQ)1. Do PPWR printing requirements apply only to exports destined for specific countries, or to the entire EU market?PPWR is an EU regulation — it is grounded directly in EU law, not in the national legislation of any individual member state. It therefore applies equally to exports destined for Germany, France, Italy, Poland, or any of the other 27 member states. Exporting to a specific country does not confer exemption from the requirements applicable in other member states; once a carton enters the EU customs union, it falls within the scope of the regulation.2. What should we do if our current carton stock does not carry PPWR-compliant printing?While it is theoretically possible to bring non-compliant stock into partial conformance by adding labels or overprints, any such additions must still satisfy the "legibility throughout the entire service life" standard required by PPWR Article 15. Subsequently applied adhesive labels are unlikely to meet this standard in the face of moisture, pressure, or mechanical abrasion. The safest course of action is to refrain from using non-compliant stock for export purposes and to replace it with a new batch produced to PPWR-compliant specifications.3. Is it the exporter's responsibility to obtain the RESY number, or does this fall to the packaging manufacturer?The RESY identification number is a system registration number that belongs to the company producing the packaging. Accordingly, obtaining and printing this number is the direct responsibility of the packaging manufacturer. What the exporting company must do is verify that its packaging supplier is registered with the RESY system, and confirm in the supplier agreement that this number is applied as a standard item to the bottom surface during production.

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