PAP 20 recycling symbol
Markings required for the EU Packaging and Packaging Waste Directive
You are likely aware that recycling symbols are becoming more prevalent across the packaging you handle and use. And this increased use of these icons and graphics is true for 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 businesses should apply to corrugated cardboard packaging. This symbol is known as PAP 20.
What is the PAP 20 logo?
PAP 20 is a recycling code/logo indicating that packaging is manufactured using corrugated cardboard. The use of 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).
The introduction of EU legislation
Reducing the environmental impact of packaging – and the waste it generates remains an important goal for the European Union.
This focus led to the introduction of the Packaging and Packaging Waste Directive 94/62/EC.
This new legislation applies to all types of packaging and aims to encourage manufacturers and distributors of packaging to use recyclable materials.
The legislation defines packaging as any item that protects and handles goods during delivery and presentation. It also incorporates secondary packaging, plus transport and storage containers used within the supply chain.
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.
PAP recycling symbols
Different types of paper recycling logos
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 – is applied to any paper-based packaging and products (including corrugated cardboard).
Whilst only 3 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.
The PAP 20 text, in conjunction with a standard recycling symbol, indicates the use of corrugated fibreboard. Many commonly refer to this material as cardboard (see an explanation of this material here). Businesses can apply this symbol to cardboard products, including transit, eCommerce and retail packaging.
PAP 21 refers to any product or packaging manufactured using a non-corrugated fibreboard. This code covers packs such as cereal boxes and gift packaging.
The number 22 inside the universal recycling symbol represents regular paper. You can use this marking on packaging such as paper bags and wrapping paper, plus newspapers, books, magazines and other products such as straws.
Is PAP 20 mandatory?
Deciding whether to include recycling symbols on your packaging
As detailed earlier, 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 3rd 2020, which includes the obligation to add material coding to packaging. Markings have become mandatory from January 1st 2022. You can download a detailed guide covering the specifics of this here (please note that the 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.
Responsibility for correct use
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 (i.e. for regions that do not explicitly require this), you declare that your packaging complies with the mandatory essential requirements of the Packaging Directive.
B2B vs B2C packaging
There are some distinctions between B2B (business to business) and B2C (business to consumer) packaging and 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.
Applying PAP 20 to your packaging
Different options for adding required symbols to your packaging
If you are required or choose to add PAP 20 to your packaging (e.g. you ship your products to Italy), you have several options.
Firstly, you can opt to print the logos directly onto the packaging. Printing is generally the most straightforward option but 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 current packaging, which may not have the relevant symbols printed. It also allows you to use the same packaging across multiple locations that have different marking requirements.
Types of PAP 20 marking
Besides the method of applying your PAP 20 markings, the legislation also permits the use of different logo types.
Whilst the coding of the PAP 20 logo is mandatory, both the regulation and EU countries do not specify in detail how the marking must appear. It is only necessary for the marking to be visible.
As such, you have a few options when marking your packs with PAP symbols.
Standard PAP 20 logo
The most widely used and accepted PAP 20 logo is the number 20 inside the standard triangle recycling symbol, with PAP text underneath. This format is consistent with the other material and recycling codes that apply to plastics, glass, and other materials.
Businesses can also use the Mobius loop recycling logo if accompanied by the PAP 20 text. The different variations of the Mobius loop are also permitted. If you already include the recycling symbol on your packaging, it allows you to simply add the PAP 20 text to existing print artwork.
To use the RESY symbol, you must hold a license/right of use from the RESY Organisation (this is a membership scheme that also has requirements for recovering and recycling paper-based packaging). However, for businesses that do, you can add the PAP 20 text to the symbol.
It may be accepted in most cases to simply use the text “PAP 20” on your packaging, providing it is clear that this refers to the material’s recyclability (this is why use with a logo is preferred).
When should you not use PAP 20
Of course, not all paper-based packaging is recyclable.
For example, any fibreboard packaging with a plastic layer – such as drinks cartons – cannot be recycled (it is too difficult and costly to separate the layers). This issue can also apply to products such as pet food bags, ice cream containers, disposal plates and other paper packaging or products that may use PAP 20, PAP 21 or PAP 22 codes.
For paper lined or mixed with plastic or aluminium materials, you should use the C/PAP 84 symbol. You may also see this referred to as PapAl.
For card stock material that has a laminate, you should use the CSL (card stock laminate) 87 symbol. This code covers products such as greeting cards, flyers, bookmarks etc.
Additional recycling codes
Symbols for all packaging materials
There is a much more comprehensive range of recycling codes and symbols, which cover more than just the paper-based materials detailed in this guide.
The longer list includes codes for differing forms of plastics (0 – 10), batteries (codes 8 – 13), metals (40 – 49), biomatter (50 – 69) and glass (70 – 79). Codes 80 to 99 currently cover composite materials.
You can view a complete list of these recycling codes here.
Copyright and correct usage
Important notice on using these packaging symbols
GWP believes the information on this page to be true and accurate at the time of writing.
However, it is your responsibility to ensure that any symbols you use on your packaging are done so in the correct manner.
GWP Group Ltd can accept no responsibility for unlawful or incorrect use of the supplied symbols. GWP can also accept no responsibility for damage or loss resulting from incorrect usage of these symbols on your packaging.
However, if you have any doubts, please get in touch using the details on this page.
Business benefits alongside regulatory requirements
EU law requires you to include the PAP 20 marking on your packaging if you ship corrugated packaging to specific regions.
But even where this scheme is voluntary, it can significantly benefit your business.
Most consumers and businesses now prefer to purchase sustainable packaging and products. Providing instructions and clarity on recycling packaging also makes life easier for your customers. Some retailers or stockists may be less keen to purchase your products if you do not include the applicable recycling logos.
As such, whilst not always mandatory, using PAP 20 logos on your packaging is generally worthwhile.
Should you have any questions regarding your business’ use of PAP 20 logos (or other recycling or material markings), please do not hesitate to get in touch.