No. As of October 2026, the EU Packaging and Packaging Waste Regulation (PPWR) does not set a minimum recycled-fiber percentage for paper or cardboard packaging. There is no general PPWR requirement for paper boxes to contain 70% recycled fiber. The mandatory recycled-content percentages in Article 7 of Regulation (EU) 2025/40 concern plastic parts of packaging, subject to specified exemptions.

For a brand choosing a rigid gift box, folding carton or small mailer, this leaves room to select virgin fiber, recycled fiber or a blend for the paper elements. That choice sits alongside the finished pack’s recyclability and other applicable requirements. The same principle applies to packaging sourced from China for the EU market: imported packaging is within PPWR’s scope, whether supplied empty or with a product.

Recycled content, recyclability and recycling targets measure different things

A box made with recycled board can still have a film, coating or insert that complicates its recycling. Virgin-fiber paper can also be suitable for material recycling. Fiber origin describes an input; recyclability depends on how the finished packaging behaves in the relevant waste stream. A recycled-content declaration therefore answers only one part of the material question.

The general Article 6 recyclability requirement has applied since 12 August 2026. Its detailed design-for-recycling condition applies from 1 January 2030 or 24 months after the relevant delegated acts enter into force, whichever is later. The absence of a paper-content quota leaves the fiber choice open; it does not remove the need to assess the packaging design.

Plastic parts can bring a paper box within Article 7

A paper box may include a transparent plastic window, film lamination or molded plastic insert. Those details deserve their own material assessment. Coatings also need to be identified by composition and assessed against PPWR’s definition of plastic; a finish’s trade name is insufficient. During development, we can coordinate the material specifications and component weights so that your team has a defined construction to assess.

Article 7(5)(b) exempts a plastic part representing less than 5% of the total weight of the whole packaging unit from Article 7’s minimum recycled-content percentages. Exactly 5% falls outside this particular exemption. The denominator is packaging weight, excluding the product.

Establishing the packaging unit comes before the calculation. Article 3(1)(45) includes both integrated and separate components within a unit that serves a packaging function as a whole. A removable insert is therefore not automatically an independent packaging unit, and an independent packaging unit cannot simply be added to the denominator. For a box, insert and outer mailer, the assessment should record which components belong to each unit.

Consider two proposed versions of a folding carton. For this illustration, the carton and its fixed 2 g plastic window form one packaging unit, the window is its only plastic part, and the total weights include all packaging materials in that unit.

The window stays the same, but reducing the board weight changes its share of the unit. This makes the material breakdown useful whenever a design changes. We can then explore a smaller window, a different presentation or a suitable recycled-plastic route alongside the lighter board, considering product protection and recyclability together.

For an in-scope plastic part in ordinary non-contact-sensitive packaging, such as a jewelry gift-box insert, Article 7(1)(d) sets an initial minimum of 35% recycled content recovered from post-consumer plastic waste—plastic discarded after use. Contact-sensitive packaging, including food-contact applications, and single-use plastic beverage bottles have separate categories; other Article 7 exemptions may also apply. The percentage concerns the plastic. Recycled fiber in the surrounding board does not count toward it.

The first-phase plastic requirements apply from 1 January 2030 or three years after the Article 7(8) implementing act enters into force, whichever is later. The statutory calculation is an average per manufacturing plant and year, for each packaging type and format. It should therefore be distinguished from a purchasing specification or claim promising a particular recycled-content percentage in every individual insert.

Article 7 also sets conditions for qualifying post-consumer plastic collected or recycled outside the EU, including equivalent collection and recycling standards. For a China-sourced packaging project, supporting information needs to address the relevant supply chain. A plastic part exempt from the recycled-content minimum still remains part of the packaging’s recyclability assessment.

Could paper receive a recycled-content target later?

PPWR provides for a review. Under Article 7(15), the Commission must review the use of recycled materials in packaging other than plastics by 12 February 2032, assess whether measures or targets are appropriate and, where appropriate, present a legislative proposal. That is a review deadline, not an automatic start date for a paper-fiber minimum. A new obligation would require further legislative action.

Choosing the paper and board for your product

With no prescribed paper-content percentage, the useful question is which grade serves each part of the pack. A wrapped rigid fragrance box might use recycled board for its structural core and a separately selected paper for the printed wrap. The core contributes stiffness and shape; the wrapping paper carries much of the color, texture and surface finish. Those different jobs give you room to combine grades deliberately.

For a folding carton, the specified grade affects panel stiffness, crease behavior and the printed surface. A pale brand color can look different when the paper’s whiteness or texture changes, so a material substitution deserves a printed sample. For a mailer carrying a heavy candle jar, the board construction, fit and cushioning work together to protect the product. A recycled-content percentage alone cannot predict those results; grade information and samples make the comparison useful.

Your brand or retailer may still have a recycled-fiber target. Treat that target explicitly as part of the sourcing brief, with a clear basis for comparing quotations and supporting any claim. Three details make a substantial difference:

• What the percentage covers: the structural board, a particular paper component, all paper elements or the complete packaging unit.
• What counts toward it: the supplier’s definition of recycled content, including the distinction between pre-consumer and post-consumer material where relevant to your target.
• What supports it: material-grade information and declarations that match the construction and materials being ordered.

A declaration for a recycled board core supports a statement about that core. A percentage claim for the finished box needs a defined calculation basis and information covering the other materials as well. Keeping this distinction visible lets you choose a suitable decorative paper or insert without losing track of what your sourcing target actually measures.

At CMIC, we can compare board and construction options, coordinate supporting material information and develop samples around your product. The result is a packaging specification that clearly identifies the paper choice, any applicable plastic-content requirement and your own sourcing target. Explore our EU packaging solutions, or share your product and current packaging brief with us to discuss those choices.