PAP 20 logo – what is it, and should you be using it on your packaging?

You are likely aware that recycling symbols are becoming increasingly prevalent on the packaging you handle and use. This trend is also evident in both consumer and industrial packaging.

Whilst many logos are only available for businesses that are part of paid schemes or have their supply chains audited, some are used purely for marketing purposes.

However, EU legislation specifies that businesses should use specific symbols to denote the material used in manufacturing the packaging. In some countries, this is a legal requirement.

Amongst the most common of these is the marking that businesses should apply to corrugated cardboard packaging. This symbol is known as the PAP 20 logo.

But what is the PAP 20 logo?

PAP 20 is a recycling code/logo indicating that packaging is manufactured using corrugated cardboard. The use of the PAP symbols is a requirement of the EU Packaging Waste Directive 94/62/EC. Other PAP codes apply to different paper-based products, including PAP 21 (non-corrugated fibreboard) and PAP 22 (regular paper).

Responsibility for adhering to regulations lies with the distributor of the packaged goods. As such, eCommerce businesses fall under the scope of the law.

Within the documentation, Article 8 explicitly defines the marking and identification of packaging materials, and this is the section that relates directly to the requirement for including packaging recycling symbols, including PAP 20.

Besides PAP 20, the European Commission defines several other paper recycling codes. These are also part of a longer list of Resin Identification Codes (RIC) and other codes that incorporate plastics, metals, glass, organic matter and even different types of batteries.

PAP – denoting paper – applies to any paper-based packaging and product (including corrugated cardboard).

Whilst only three PAP codes are currently defined, the EU has reserved numbers 20 to 39 for other paper-based products.

The currently defined PAP codes are as follows:

As detailed previously, the Packaging and Packaging Waste Directive 94/62/EC, and specifically Decision 97/129/EC, specifies the identification codes for packaging materials.

Whilst the legislation indicates that using the identification system is voluntary, two EU members, Italy and Bulgaria, have made the coding mandatory.

Italy introduced Legislative Decree No. 116 on September 3, 2020, which includes the obligation to add material coding to packaging. Markings have become mandatory as of January 1, 2022. You can download a detailed guide covering the specifics of this here (please note that this guide is in Italian).

This legislation ultimately means that if you are supplying products to these countries, your packaging must comply with the requirements and display the applicable markings.

The responsibility for correctly using the recycling symbols, including PAP 20, falls to you as the distributor of your goods.

Please also note that when you apply voluntary marking to your packaging (e.g., for regions that do not explicitly require this), you declare that your packaging complies with the mandatory essential requirements of the Packaging Directive.

There are distinct differences between B2B (business-to-business) and B2C (business-to-consumer) packaging, as well as the logo requirements for each.

For B2C packaging, particularly eCommerce, the relevant logo must be directly on the packaging. In rare instances where this is not practical, it may be possible to include the marking and appropriate instructions for recycling in accompanying literature (e.g., product instructions). To avoid any issues, always aim to have the PAP 20 logo on the packaging itself.

For B2B packaging and applications, however, most countries accept marking and logos via the accompanying shipping documents.

If you are required or choose to add PAP 20 to your packaging (e.g., when shipping products to Italy), you have several options.

Firstly, you can opt to print the logos directly onto your packaging. Printing is generally the most straightforward option, but it may incur additional setup costs (such as new printing plates).

Secondly, you can use a perforation to create the marking, similar to printing. This method may involve changes to your tooling, however.

The final option, which is generally accepted, is to apply a label to your existing packaging. This option allows you to use your current packaging, which may not have the relevant symbols printed on it. It also allows you to use the same packaging across multiple locations that have different marking requirements.

There is a much more comprehensive range of recycling codes and symbols, which cover materials beyond those detailed in this guide, including paper-based materials.

The longer list includes codes for differing forms of:

• Plastics (0-10)
• Batteries (8-13)
• Metals (40-49)
• Biomatter (50-69)
• Glass (70-79)
• Composite materials (80-99)

You can view a complete list of these recycling codes here.

You can also view our comprehensive guide for a more detailed explanation of packaging recycling symbols applicable to corrugated packaging. Here, you can download a selection of the most commonly used icons as well.