Paper-based packaging can fall within plastic-specific PPWR rules when it includes a plastic film, barrier, window or other component. Paper being the main material does not settle every obligation: a pack can belong to a paper/cardboard category for recyclability while its plastic content remains relevant to recycled-content requirements or a restriction on a particular use. There is no universal percentage that exempts paper packaging from all plastic-related requirements.

A laminated promotional sleeve, a windowed skincare carton and a gift box with a plastic insert can therefore lead to different decisions, even when all three are described as paper packaging. The Packaging and Packaging Waste Regulation, Regulation (EU) 2025/40, generally applies from 12 August 2026. The format restrictions in Article 25 and Annex V begin on 1 January 2030.

Identify the plastic in the finished pack

A specification such as “paperboard carton with a matte finish” leaves important details unresolved. The surface could be a plastic laminate or a coating with a different composition. At CMIC, we can help turn a sample or design brief into a description of the actual construction, so the material assessment starts with what will be manufactured.

• Films and laminates: identify the polymer, its weight, and how it is bonded to the paper.
• Coatings and barriers: establish the dry composition, applied weight and function of the layer.
• Windows, labels, liners and inserts: record their materials, weights and attachment methods.
• Packaging-unit boundaries: establish which parts form the unit being assessed and how its components are intended to separate during use.

For a coating, the relevant information concerns the material left after drying. The amount of liquid coating used during production does not tell you how much plastic remains on the finished pack. Similarly, a glued window and a loose insert need different descriptions: their attachment and removal affect how the packaging is assessed.

The different 5% rules answer different questions

Article 3(1)(24) defines composite packaging around a packaging unit combining different materials that cannot be separated manually and form a single integral unit, subject to specified exceptions. That definition, the recycled-content exemption and the interpretation of the plastic-format bans each give the figure 5% a different job.

Exactly 5% needs care. Section 17 of the Commission’s draft guidance describes packaging containing “5% or more plastic” as covered, then says packaging containing “not more than 5%” is outside the ban. Those statements overlap at 5%. The draft is interpretive and does not amend the regulation; it does not provide an unambiguous answer for a design at that boundary. Article 25(6) requires further Annex V guidelines by 12 February 2027. A design relying on the boundary needs confirmation against the applicable official interpretation before approval.

Article 7’s boundary is clearer. Suppose a finished packaging unit weighs 40 g, including a 2 g plastic part. That part represents 2 ÷ 40 × 100 = 5%, so it does not qualify for the less than 5% exemption. A 1.6 g plastic part within a 40 g finished unit represents 4%. Establish the packaging unit before calculating the percentage; the product’s weight is not part of the denominator.

This plastic share is also different from the recycled-content target itself. Where a target applies, it concerns recycled content in the plastic part; recycled paper cannot satisfy it. The applicable target depends on factors including the packaging category and polymer. These requirements begin on 1 January 2030 or three years after the implementing act under Article 7(8) enters into force, whichever is later.

Match the construction to the packaging’s use

A laminated sleeve around a promotional twin-pack

Consider a single-use paperboard sleeve grouping two separately saleable bottles into a promotional retail twin-pack. If its bonded plastic film accounts for 8% of the finished sleeve’s weight, it falls within the plastic-content scope described in the draft guidance. Its use also makes Annex V point 1 relevant: that provision covers single-use plastic grouped packaging used at the point of sale to group goods in bottles, cans, tins, pots, tubs and packets as convenience packaging enabling or encouraging consumers to buy more than one product.

Point 1 excludes grouped packaging necessary to facilitate handling. That exception needs a functional assessment; the Commission FAQ says further guidance will explain how it operates. Replacing shrink wrap with a laminated paper sleeve can therefore leave the same restriction relevant. A useful development route is to sample an unlaminated board sleeve, checking whether its structure holds the bottles securely and whether the printed surface has adequate scuff resistance. The sample helps establish which jobs the original film was doing and how to provide them in the revised construction.

A windowed carton around one skincare product

An ordinary retail carton containing one skincare jar has a different use. A PET window does not turn it into the promotional grouped packaging described in point 1, or by itself establish another restricted Annex V use. The window still matters to the applicable Article 7 recycled-content assessment and to Article 6 recyclability, including the interaction between the window, adhesive and paperboard.

The design question is whether seeing the actual product earns the window’s place. An open window removes the film but exposes the product surface to dust and handling. Replacing the window with a printed image preserves the enclosure while changing the shopper’s view of the product. These alternatives deserve comparison against the presentation and protection the carton needs to provide.

A rigid gift box with a plastic insert

A gift box can combine a paper shell and a plastic insert within one packaging unit. Under Article 6(9), separate components receive separate recyclability assessments, while integrated components are included in the unit’s assessment. Being removable by hand does not, by itself, settle the insert’s component status: its intended removal when accessing the product and its relationship to the main packaging body matter. The Commission FAQ illustrates this distinction through components that must be completely and permanently removed to access a product.

A separate recyclability assessment also does not automatically create a different packaging unit for the Article 7 weight calculation. Where the box and insert form one unit, that unit supplies the denominator. Meanwhile, a paperboard or moulded-pulp replacement needs to do the insert’s physical work. For a fragrance bottle, the support points, clearance around decorated surfaces and ease of lifting the bottle out deserve attention alongside the material change.

Food-service packaging adds another scope question. Certain paper cups and food containers containing plastic can also fall under the Single-Use Plastics Directive and associated national measures. PPWR’s composite-packaging definition expressly preserves that separate regime. A low plastic share under one PPWR test does not resolve those obligations.

For the wider set of restricted uses, see our guide to PPWR packaging format restrictions and redesign before 2030. The material assessment here helps establish which of those restrictions deserves attention for a particular paper-based construction.

What water-based, bio-based and biodegradable establish

• Water-based describes the coating’s liquid carrier. After the water evaporates, the remaining layer may contain plastic polymers. Its dry chemistry and function need to be identified before deciding its treatment.
• Bio-based concerns feedstock origin. A polymer can be partly or wholly derived from biomass and remain plastic. PPWR addresses biobased feedstock in plastic packaging in Article 8; renewable origin does not automatically remove a material from plastic-specific rules.
• Biodegradable or compostable concerns breakdown under particular conditions. Annex II expressly includes biodegradable plastics such as PLA and PHB within plastic categories. A compostable PLA window remains a plastic window. Outside the specified compostable-packaging cases, Article 9(3) requires packaging—including biodegradable plastic packaging—to be designed for material recycling by 12 February 2028.

Inks, adhesives and labels also need their rule-specific treatment. The composite-packaging definition excludes labels, varnishes, paints, inks, adhesives and lacquers. Separately, the Commission FAQ says adhesives, paints and inks are not deemed plastic for the recycled-content requirements. Yet its plastic-label example still applies the Article 7 low-weight test to the label. An exclusion in one definition cannot simply be carried across to another requirement.

This is why a supplier description such as “water-based protective finish” needs supporting detail. Identify whether the applied material is a varnish, adhesive, plastic barrier or another construction, rather than inferring its treatment from the sales name. Its effects on recycling remain relevant: Annex II specifically considers adhesives, barriers, coatings and printing materials in the recyclability assessment.

Make the next sample answer the important questions

Material classification and recycling performance need to be considered together. Annex II recognises paper/cardboard composites with plastic laminations, liners and windows, but that category alone does not demonstrate the finished pack’s recyclability. A high paper percentage describes composition; it does not establish how efficiently fibres can be recovered or how adhesives and barriers affect the resulting material.

Article 6 contains a general recyclability requirement across packaging materials. Its harmonised design-for-recycling and grade-based market-access requirements apply from 1 January 2030 or 24 months after the relevant delegated acts enter into force, whichever is later. Avoiding an Annex V restriction therefore answers only one part of the design assessment.

For an EU-facing packaging project, we can help gather composition and component-weight information, develop alternative materials and structures, and coordinate appropriate testing. A useful comparison shows which layer or component changed, how that affects the relevant assessment, and what happened to fit, surface protection and opening experience. For a windowed carton, that might mean comparing visibility and enclosure; for a rigid box, it might mean comparing how two insert constructions restrain the same product.

If you are reviewing a paper-based pack for the EU, contact CMIC with its current sample or specification, intended use and the qualities you want to preserve. Those details give us a practical starting point for developing a construction whose materials, function and compliance evidence can be considered together.