EU PPWR: Honeycomb Board Labeling and Printing Standards
Author: Arkas Ambalaj Technical Team | Category: Regulation & Compliance | Updated: 05/2026For companies exporting to the European Union, the export box and corner protectors usually take center stage on the PPWR compliance agenda. However, paper honeycomb board included within the same shipment is defined as "packaging" under the PPWR (Packaging and Packaging Waste Regulation) and is subject to the exact same printing, marking, and traceability obligations as the export box.Despite its lightweight nature and simple appearance, paper honeycomb board is a technical packaging component that falls under independent scrutiny during EU customs inspections. A honeycomb panel that does not bear the necessary PPWR markings can constitute grounds for non-compliance on its own, even if the export box in the same shipment meets all requirements flawlessly.This guide has been prepared to help companies exporting to the European Union or preparing to enter this market, along with packaging procurement managers, fully grasp the PPWR requirements applicable to kraft paper-based brown paper honeycomb board at a technical level.What is PPWR and Why Does It Directly Concern Paper Honeycomb Board?PPWR is a new generation regulation replacing the EU's old Packaging Directive 94/62/EC. Unlike a directive, a regulation does not wait to be transposed into the national legislation of member states; it is applied directly and equally in all member countries as soon as it enters into force. For every exporter entering the EU market from Türkiye, this represents a uniform and mandatory compliance obligation.The regulation aims to increase recycling rates, reduce packaging waste, and embed circular economy principles into every link of the supply chain. In this context, paper honeycomb board is treated not merely as a buffer, divider, or support element, but as a technical packaging component that carries identification information, ensures traceability, and contributes to the recycling system.Which Packaging Category Does Paper Honeycomb Board Fall Into?PPWR defines packaging according to functional categories:Primary packaging: Packaging in direct contact with the product.Secondary packaging: Grouping packaging that holds primary packages together.Tertiary / Transport packaging: Any packaging component that protects products from damage during transport and storage.Depending on its area of use, paper honeycomb board can occupy different levels of this classification, but its most common functions in export shipments are:Palet divider (interlayer board): Placed between pallet layers to prevent products from damaging each other.Buffer and void-fill panel: Protects the product against impact by filling voids inside the box.Support and base board: Provides structural support at the base of the pallet or under the product.Edge and surface protection panel: Protects the edges and surfaces of large-surface products.In all these forms of use, paper honeycomb board falls under tertiary packaging. The definition in Article 3 of the PPWR explicitly covers these functions.Practical consequence: The moment paper honeycomb board enters EU customs, it is subject to the same regulatory oversight as the export box.The Material Identity of Paper Honeycomb Board: 22 PAPThe paper honeycomb board addressed in this guide is a completely paper-based composite panel material consisting of a kraft paper-based honeycomb core and kraft paper surface linings (liners). Its brown color is characteristic of unprocessed natural kraft paper.In the European Commission's standard coding system for packaging materials, this structure, which consists predominantly of paper-based material, is defined by the code 22 PAP.MaterialCodeAbbreviationApplication AreaCorrugated Cardboard20PAPExport boxSolid / Solid Board21PAPCardboard corner protectorKraft Paper / Paper Honeycomb Board22PAPPaper honeycomb board (standard)Technical Note: The material code for paper honeycomb board may vary depending on the raw material composition. If board is used for the surface linings (liners), the code can also be applied as 21 PAP. The producer must determine and document which code to use based on the raw material certificate. Arkas Ambalaj provides proof documentation to the exporter by matching the raw material certificate with the code allocation for every production batch.PPWR Article 15 and Article 18: The Core Compliance FrameworkThe two primary articles directly regulating the printing and marking obligations on paper honeycomb board are:Article 15 — Packaging Information: It is mandatory that all information and symbols on the panel remain readable, indelible, and verifiable throughout the lifecycle of the component — throughout the process from production to transport, storage to the recycling facility. This information must be resistant to physical conditions such as humidity, pressure, friction, and temperature changes in logistical processes.Article 18 — Traceability and Identity: The panel must carry a unique identification number that enables traceability and must contain information that allows the manufacturer or importer to be identified. This article ensures that the packaging component does not break its bond with the actor placing it on the market.When both articles are evaluated together, the picture is clear: Paper honeycomb board must be designed during the production process in terms of the permanence and accuracy of the information on it.Physical Printing Rules: Material, Color, and FontThe physical standards for printing on paper honeycomb board share the same parameters as other paper-based packaging components:ParameterMandatory StandardBackground MaterialNatural brown kraft paper surface of the panelPrinting ColorBlackFontArialReadabilityIndelible throughout the entire lifecycleThe main reason for these rules is practical: Black Arial print on a brown kraft surface ensures maximum readability by optical character recognition (OCR) systems in recycling facilities and by handheld barcode scanner sweeps. Different color or font combinations can cause scanning errors, breaking the traceability chain.In this regard, the brown kraft surface of paper honeycomb board possesses the same optical characteristics as the natural brown background of export boxes; black printing naturally meets standard requirements for contrast and readability.PPWR Article 15 and 18 Compliance: Printing Durability and Avoiding LabelsArticles 15 and 18 of PPWR mandate that information on the packaging component must remain readable throughout its entire lifecycle. At this juncture, a critical technical decision emerges: The use of adhesive labels is a high-risk method for meeting PPWR's durability requirements.Paper honeycomb board is exposed to unique conditions due to its structural properties, making this risk even more pronounced:Surface porosity: The natural porous structure of kraft paper leads to uneven penetration of the label adhesive, creating weak adhesion at the label's edges.Pallet stretch film pressure: Stretch film applies uneven pressure to the panel surface. The honeycomb voids beneath the panel locally increase this pressure, causing the label to curl or peel off.Container and warehouse humidity: The humidity cycle in sea transport, combined with kraft paper's moisture absorption property, weakens the label adhesive; the label may lift from the surface.Static pressure and friction: The panel is exposed to friction caused by the weight and movement of products within the pallet; these conditions can mechanically destroy the label.Cold chain conditions: In condensation environments, the bond strength of the label adhesive decreases, and the label surface bubbles.During customs inspections, any of this damage turns into a non-compliance report under the grounds of "unreadable inscription."Arkas Ambalaj's technical approach:Direct printing is applied to the panel's kraft paper surface using high-durability water-based black ink instead of labels.Prints are tested via ASTM D5264 (Sutherland rub test) and ISO 18947 (abrasion resistance) industrial protocols.The readability of the printing throughout all logistical processes is verified and documented with humidity chamber tests (95% humidity, 48 hours at 40°C), static load tests, and drop tests (ISTA 1A).Compliance certification is issued to the exporter firm, conducting these tests in Arkas Ambalaj's own laboratory or accredited external facilities for every batch of paper honeycomb board.Why Direct Printing, Not Labels?The surface structure of kraft paper and the internal structure of paper honeycomb board make the use of labels physically problematic. PPWR's principle of avoiding unnecessary chemicals adopts direct printing as the fundamental approach.Basic Rules and Why Labels Are Excluded:Color — only black: Colored labels or pigment-inked labels disrupt the de-inking process during recycling. Arkas Ambalaj ensures 100% recovery of the paper pulp by using water-based black ink.Font — Arial or sans-serif: Even if the correct font is used on the label, the font requirement is deemed violated if the label separates from the kraft surface. In direct printing, the font is an integral part of the material.Adhesive contamination: Acrylic or hot-melt adhesives used in labels cause contamination in the recycling pool. PPWR Annex II (Recycling Compatibility Criteria) restricts such adhesives.Pressure distribution of the honeycomb structure: A label applied to the panel remains suspended over the open areas of the honeycomb cells; adhesion occurs only at the top points of the cell walls. This can effectively reduce the label's surface adhesion area by up to 30-40%.Arkas Ambalaj's Testing and Approval Processes:Rub test: With a Sutherland rub tester, after 2 kg pressure and 10 double rubs, print loss must be ≤ 5%.Scotch tape test (ASTM D3359-Method B): Adhesion resistance of the print to the surface must be at level 4B or 5B.Wet rub test: There must be no bleeding or erasing of the print in condensation environments.UV fading test (ISO 12040): Color change ΔE ≤ 1.5 after 24 hours under a Xenon lamp.Application Note: In flexo or digital printing technologies, ink penetration and density must be adjusted according to the absorption characteristics of the kraft paper surface of the paper honeycomb board. Ink viscosity and printing speed are production variables that must be calibrated according to surface roughness and porosity parameters. This is the technical responsibility of the packaging manufacturer.External (Top) Surface Printing ObligationsThe outward-facing surface of the paper honeycomb board — the kraft paper surface visible within the shipment or on the pallet — is the primary area carrying logistics and regulatory identity. Under PPWR, the following elements must be completely included on this surface:1. Exporter / Manufacturer Company Identity InformationFull commercial address of the company (at street, city, country level)Website address and/or other digital communication channelsThis information is mandatory for EU customs authorities and market surveillance agencies to quickly identify the placed on the market actor.2. ISO 7000 Series Symbols EU legislation mandates the use of international graphic symbols to identify the actor placing the packaging component on the market:ISO 7000-3082 Symbol: Used by the company that personally manufactured the paper honeycomb board (Manufacturer).ISO 7000-3725 Symbol: Used by the company that placed the paper honeycomb board on the EU market but did not personally manufacture it (Importer).Every exporter must use only one of these two symbols according to their role in their supply chain. Concurrent use of both or selection of the wrong symbol constitutes grounds for direct non-compliance.3. Unique Packaging ID (Packaging ID) It is mandatory that honeycomb panels belonging to every production batch carry a unique Packaging ID registered in the system. This identification number links the panel to the production batch, material certificate, and traceability record.Production Date: Specifying it in the format of week order and year (e.g., W18/2025) is optional; however, it provides strong practical convenience in terms of supply chain management and potential recall procedures.Back / Bottom Surface (Recycling) Printing ObligationsThe back or bottom surface of the paper honeycomb board, which is in contact with the product or the pallet surface, is the mandatory area reserved for recycling information. All symbols on this surface must be visible and legible not while the panel is in the shipment, but after the panel is separated from the product or pallet — that is, when it enters the waste management process.This placement rule is operationally mandatory for automated classification systems in recycling facilities to direct the panel to the correct flow.Basic elements mandatory on the back / bottom surface are listed below:1. Recycling Logo The standard recycling pictogram indicating that the packaging component is a recyclable material must be included in this area. Paper honeycomb board, with its 100% paper-based structure, is a material with high recovery value in the recycling system; indicating this feature visually with the logo is a mandatory requirement in terms of legislation and a functional requirement in terms of the circular economy.2. RESY Symbol and RESY Identification Number RESY is the trademarked symbol of the recycling and recovery system operated for transport packaging in Europe. The system has entered mandatory application in many EU member countries, particularly Germany.The RESY logo must be visually present on the back/bottom surface of the panel.In addition, the RESY member/identification number belonging to the packaging manufacturer that produced the panel must be included in text format.This number proves that the packaging manufacturer is registered in the RESY system; it relieves the exporter firm from the responsibility of independently verifying whether the manufacturer fulfills its system registration obligation. Arkas Ambalaj's RESY identification number is printed as standard on the back/bottom surface of every batch of paper honeycomb board produced.3. "22 PAP" Material Identification Code In the European Commission's standard coding system, kraft paper-based paper honeycomb board is defined with the code 22 PAP.Both the numerical code (22) and the abbreviation (PAP) must be written together on the back/bottom surface.This code is mandatory for recycling facilities to automatically direct the material to the correct paper recycling stream.MaterialCodeAbbreviationCorrugated Cardboard20PAPSolid / Solid Board21PAPKraft Paper / Paper Honeycomb Board22PAP4. Triman Logo Triman is French-originated and has now become a standard symbol system for packaging recycling information in multiple EU member countries. The use of the Triman logo is mandatory for all tertiary/transport packaging components, including paper honeycomb board.Triman warns the consumer and the waste management operator that the packaging component is recyclable in nature. It is the visual component of the circular economy infrastructure aimed at reducing emissions arising from incorrect waste classification. The 100% paper-based structure of paper honeycomb board directly overlaps with the "single material, full recycling" principle targeted by the Triman system.Customs and Market Risks of Non-ComplianceSince 2024, customs and market surveillance authorities of EU Member States have implemented systematic inspections covering all transport packaging components, including paper honeycomb board. Risks encountered in practice are:Shipment hold: Paper honeycomb panels bearing missing or unreadable print information constitute sufficient grounds alone for the detention of the entire shipment at customs.Product return: Detection of a wrong symbol, missing code, or unreadable inscription may lead to the return of the entire batch to the exporter.Administrative fine: Placing a product on the market with a non-compliant packaging component is subject to direct sanctions under member state legislation.Brand reputation damage: Large-scale buyers, particularly in Germany, France, and the Netherlands, now include packaging components within the standard scope of supplier competency audits. A non-compliance arising from paper honeycomb board directly affects the respective exporter's supplier record negatively.Paper Honeycomb Board PPWR Compliance with Arkas Ambalaj: Technical Procurement SolutionsAs one of Türkiye's long-established industrial packaging manufacturers, Arkas Ambalaj has created an integrated compliance framework covering paper honeycomb board production with the entry into force of PPWR.Technical standards offered by Arkas Ambalaj in the paper honeycomb board production process:PPWR Article 15 and 18 compliant printing design: All information fields are technically verified before production according to the permanence, readability, and placement standards mandated by the regulation. Ink viscosity and printing parameters suitable for the unique surface structure of kraft paper are calibrated on the production line.22 PAP material code application: The code suitable for the kraft paper raw material structure is applied as standard on the production line, matched with the raw material certificate for every batch.ISO 7000 series symbol integration: The correct symbol is included in the printing template according to the customer's role in the supply chain.RESY membership infrastructure: Arkas Ambalaj's RESY identification number is printed as standard on the back/bottom surface of every batch of paper honeycomb board produced; it secures the exporter firm in terms of system compliance.22 PAP, Triman, and recycling logo printing: Applied on the production line in accordance with the back/bottom surface placement rules.Packaging ID allocation: A unique identification number is generated for every production batch and matched with the exporter document set.Durability test protocol: Printing permanence is documented for every batch with the Sutherland rub test, Scotch tape test, humidity chamber test, and UV fading test, and a compliance certificate is issued.The integration of these steps into the production process by the packaging supplier significantly reduces the manual control burden on exporters before every shipment and systematically eliminates the risk of non-compliance.Summary: Paper Honeycomb Board PPWR Compliance ChecklistThe following table is the basic checklist that every exporter and packaging procurement manager can use in the production approval process:AreaMandatory ElementStandard / SourcePhysical PrintingBlack ink, Arial font, brown kraft backgroundPPWR Article 15External / Top SurfaceCompany full address + websitePPWR Article 18External / Top SurfaceISO 7000-3082 or ISO 7000-3725 symbolISO 7000 SeriesExternal / Top SurfaceUnique Packaging IDPPWR Article 18External / Top SurfaceProduction date (W/Year)OptionalBack / Bottom SurfaceRecycling logoPPWR Article 15Back / Bottom SurfaceRESY symbol + manufacturer RESY numberRESY System RulesBack / Bottom Surface22 PAP codeAB Packaging CodingBack / Bottom SurfaceTriman logoTriman SystemGeneralAll prints readable throughout panel lifePPWR Article 15Frequently Asked Questions (FAQ)1. Paper honeycomb board is an auxiliary material placed inside the export box; are PPWR requirements really applicable to this component as well? Yes, applicable without exception. PPWR Article 3 defines any material that protects the product from damage and contamination, and facilitates the storage and transport process, as "packaging." Paper honeycomb board directly meets this definition. The regulation bases it not on whether a packaging component is "auxiliary" or "small," but on whether it performs a packaging function. EU customs inspection officers follow this distinction exactly in practice.2. Must the material code for paper honeycomb board be 22 PAP, or can a different code also be used? The material code is determined according to the raw material composition of the panel. The 22 PAP code is suitable for paper honeycomb board whose core and surface linings consist of kraft paper. However, if board is predominantly used for the surface linings (liners), the code can be evaluated as 21 PAP. This distinction must be based on the raw material certificate of the manufacturer and documented for every batch. The use of a wrong code leads to the misdirection of the material to the faulty stream in the recycling facility and regulatory non-compliance. Arkas Ambalaj eliminates this risk at its source by matching the raw material certificate with the printing code in every batch production.3. Must the exporter provide the RESY number, or is this the responsibility of the packaging manufacturer? The RESY identification number is a systemic registration number belonging to the firm manufacturing the packaging component. Therefore, the provision and printing of this number are directly the responsibility of the packaging manufacturer. What the exporter firm needs to do is verify whether the packaging manufacturer it procures from is registered in the RESY system and confirm in the supplier contract whether this number is applied as standard to the back/bottom surface on the production line.This article has been prepared by the Arkas Ambalaj technical team for general information purposes. You can contact the Arkas Ambalaj sales engineering team for compliance assessment and technical support specific to your paper honeycomb boards.











