Paper can replace some single-use plastic formats restricted by the EU’s Packaging and Packaging Waste Regulation (PPWR). A paperboard sleeve may replace plastic film around a retail multipack. A paper wrapper around a miniature hotel soap intended for one booking, however, leaves the restricted use in place. The difference comes from whether the rule targets plastic specifically or the packaging use regardless of material.

For a brand considering paper packaging alternatives to plastic, three decisions belong together: whether the replacement addresses the applicable restriction, whether it protects and presents the product, and whether its complete construction supports the intended recycling route. A coating that makes paper usable can change both its legal assessment and how it behaves during recycling.

Where switching to paper can address the restriction

The PPWR has applied generally since 12 August 2026. Its Article 25 and Annex V restrict placing specified packaging formats on the EU market for specified uses from 1 January 2030. Five of Annex V’s six entries specify plastic; the accommodation-sector entry does not. This creates different opportunities for paper replacement.

Paper options also need a destination-market check. Article 25(2) allows Member States to retain restrictions adopted before 1 January 2025 on the same Annex V formats and uses made from materials not listed in the Annex. A paper replacement can therefore fall outside a plastic-specific EU restriction while remaining affected by a retained national rule. Our guide to PPWR packaging format restrictions before 2030 explains the wider redesign context.

A retail multipack needs a structure that holds the products

Consider two individually saleable skincare pots shrink-wrapped as a promotional pair. The film makes the offer recognizable and grips the pots. With paperboard, retention comes from the structure: an open-ended sleeve can look tidy while allowing a smooth pot to slide out. Folded ends, a shaped base or a locking feature can keep the products together without enclosing every face.

The way someone picks up the pack matters. A carrier lifted by its handle must support the combined product weight. A narrow band around products supported in a display tray has a different job, although it still needs to survive normal customer handling. Board thickness alone does not resolve this difference; the position of folds, openings and load-bearing panels determines how forces pass through the pack.

At CMIC, we can develop a small number of structures around the actual products, then compare retention, opening and packing effort before detailed artwork is settled. Product size variations and humid conditions can expose a fit that seemed convincing on a desk sample. For packaging manufactured in China and destined for the EU, we can coordinate sample checks around the customer’s actual packing and shipping route. The useful result is a clear comparison showing where extra board earns its place and where it can be removed.

Sometimes the promotion can work with separately handled units. A bundled price or shelf communication may then remove the need for grouping packaging altogether. That option deserves consideration before developing a replacement sleeve, particularly when each product already has adequate protection and labeling.

Barrier performance has to survive the finished pack

Most paper and board are porous and absorb water. A barrier treatment can extend their useful range, but resistance to liquid water, grease, water vapor and oxygen are different properties. Grease resistance may prevent an oily product from staining the outside of a box. A water-vapor barrier controls moisture exchange, which can affect texture or shelf life. One favorable test result does not establish all of these functions.

A café replacing a disposable plastic meal box needs the paper version to hold hot, oily food for the intended serving time. The coating may perform well on a flat sheet while folds, seams or cut edges create weaker points in the finished box. Heat and steam can also change how the board holds its shape. A useful comparison therefore uses formed packs under representative food, temperature, holding-time and handling conditions. The question is whether the meal remains contained and the box remains comfortable to carry and eat from.

A technical discussion of paper barriers by Siegwerk identifies the base paper, coating weight, coverage and drying conditions as consequential variables. More coating can improve a barrier while increasing drying demands and the risk of coated surfaces sticking together. This is why a coating name alone is a weak specification: the coating, paper and converting process must work together. For food packaging, the selected construction also needs appropriate food-contact evidence for its intended conditions of use.

Coatings change the legal assessment

Terms such as “water-based” and “dispersion-coated” describe how a coating is formulated or applied. After drying, the remaining barrier can contain a polymer that meets the legal definition of plastic. Likewise, a bio-based or biodegradable plastic does not automatically become a non-plastic material. The polymer’s identity and function matter; unmodified natural polymers have a specific exclusion under the plastic definitions.

The 5% figure has a limited role. Sections 16–17 of the Commission’s March 2026 draft PPWR guidance interpret Annex V points 1–4 as covering paper-based composites containing plastic, while treating packaging below 5% plastic by mass as outside those particular bans. The reasoning draws on the composite-packaging definition and the total mass of the packaging unit.

The March document was issued as a draft for later formal adoption, and its wording conflicts at exactly 5%. A design relying on that interpretation needs confirmation against the applicable final guidance before approval. It does not establish an exemption from the rest of the PPWR or from separate single-use-plastics requirements.

A separate provision, PPWR Article 7(5)(b), exempts a plastic part representing less than 5% of the total weight of the whole packaging unit from the minimum recycled-content requirements in Article 7(1)–(2). That provision concerns recycled content. It does not authorize a format otherwise restricted by Article 25.

The Single-Use Plastics Directive, Directive (EU) 2019/904, uses a different approach. Its definition covers products made wholly or partly from plastic, and the Commission’s 2021 guidance confirms that there is no minimum plastic-content threshold. Paper products with a plastic coating or lining can therefore fall within the Directive when they meet one of its covered product categories.

A single-use paper plate with a plastic barrier coating falls within the Directive’s plate restriction, whose market prohibition has applied since 3 July 2021. A plastic-lined paper beverage cup belongs to a different category, with marking, consumption-reduction and extended producer-responsibility requirements; the existing cup prohibition concerns expanded polystyrene. Where a cup or qualifying food container falls outside a particular PPWR ban but remains within the Directive, national consumption-reduction measures may still apply. The product category matters alongside the material composition.

For a purchasing decision, the useful document is a material breakdown of the finished packaging, identifying its coatings, liners, windows and other components. Ordinary inks, adhesives and certain papermaking processing aids have distinct treatment in the single-use-plastics guidance, so the mere presence of a polymer is not a complete assessment either. We can help connect the sample and material specification with information from the relevant material suppliers, keeping the agreed construction clear as the project develops.

Hotel toiletries require a change in how the product is supplied

A paper sachet around hotel bar soap is a particularly revealing example: sachets around bar soap are expressly listed among Annex V point 5’s illustrations. A dry soap may be easier to package in paper than a liquid shampoo, but that technical advantage does not resolve the restriction. If the packaging is intended for one booking only and to be discarded before the next guest arrives, changing its material leaves those conditions intact.

A more useful route to explore is a dispenser intended to remain in service across bookings, supported by an appropriate refill arrangement. That changes the work required from the packaging: compatibility with the formulation, controlled dispensing, cleaning or replacement procedures, and convenient replenishment become central. The product supplier and accommodation operator need a workable method that preserves hygiene and the guest experience. Simply changing the appearance or size of a pack still discarded after each booking does not make that operational change.

Paper can still contribute through cartons for refill supplies, transport protection and printed product information. CMIC can help develop those paper components around the chosen delivery method and coordinate suitable adjacent components where needed. The paper specification follows the service arrangement, giving the hotel something practical to receive, store and replenish.

Compare the complete pack, including its recovery route

Repulpability describes how a paper construction breaks down during fiber recovery. Testing can reveal how much usable material is recovered and what remains as rejects. Actual recycling also depends on collection, sorting and a suitable receiving process in the destination market. Evidence should therefore match the finished construction—including its coatings, windows, labels and adhesives—and the route available after use. A successful laboratory result and an available recycling route answer related but different questions.

The commercial comparison should be equally complete. A narrow band may use little material but require additional folding or locking during packing. A fuller carton may add weight and shipping volume while reducing movement or replacing a separate protective insert. Comparing material price alone misses those exchanges. Samples and a packing trial can make assembly time, product retention and the number of components visible before a production decision.

If the aim is lower environmental impact, compare options providing equivalent protection for the same product and distribution conditions. Material quantity, product damage, transport and the likely recovery route all affect the result. A claim about lower carbon emissions needs a suitable life-cycle basis; a reduction in plastic content establishes a narrower, different fact.

For a specific redesign, our EU packaging solutions work can begin with your existing pack, the product, the intended markets and the job the packaging must perform. We can develop paper structures, compare samples, coordinate material information and arrange appropriate testing around the selected route. That gives your team a concrete choice between removing a pack, developing a paper replacement and changing how the product is supplied.