What is the PAP 20 logo, and should you be using it?

Recycling symbols are now a familiar sight on almost every type of packaging, from consumer products to industrial transit packs. As sustainability expectations increase and legislation evolves, these markings are becoming an essential consideration for businesses of all sizes.

Some recycling logos are linked to paid membership schemes or audited supply chains, while others are applied voluntarily as part of a brand’s sustainability messaging. However, EU legislation also defines specific material identification symbols that businesses are expected to use to indicate the materials from which packaging is made. In certain countries, this is not optional.

One of the most common examples is the PAP 20 logo, which applies to corrugated cardboard packaging. Understanding what this symbol means and when to use it is particularly important for businesses shipping goods across borders.

1. What is the PAP 20 logo?
2. Why were material codes introduced?
3. PAP codes explained
4. Is it mandatory?
5. Who is responsible? 
6. What is the difference between B2B and B2C packaging?
7. How do you apply to your packaging?
8. When should you not use it? 
9. Summary

PAP 20 is a material identification code that indicates packaging is manufactured from corrugated fibreboard, commonly referred to as cardboard. It forms part of the EU’s material coding system introduced under the Packaging and Packaging Waste Directive 94/62/EC.

The PAP codes apply specifically to paper-based materials. While PAP 20 relates to corrugated cardboard, other codes exist for different paper products, such as PAP 21 for non-corrugated fibreboard and PAP 22 for regular paper.

Using the correct code helps to ensure that your packaging is correctly identified and recycled at the end of its life, particularly when it enters waste streams in different countries.

Reducing the environmental impact of packaging waste has long been a priority for the EU. This led to the introduction of the Packaging and Packaging Waste Directive, which applies to all forms of packaging, including primary, secondary, and transport packaging used throughout the supply chain.

The legislation defines packaging broadly, covering anything used to contain, protect, handle or present goods. Importantly, responsibility for compliance sits with the distributor of the packaged goods, not the packaging manufacturer. This means eCommerce businesses, exporters and product suppliers all fall within scope.

Article 8 of the Directive addresses the marking and identification of packaging materials. This is the section that underpins the use of recycling and material identification symbols such as PAP 20.

All PAP codes relate to paper-based materials. Although only a smaller number are currently defined, the EU has reserved numbers 20 to 39 for future paper and fibre-based packaging types.

• PAP 20 is used for corrugated fibreboard and applies to most transit cartons, shipping boxes, and eCommerce packaging.
• PAP 21 is used for non-corrugated fibreboard, such as cereal boxes or retail cartons.
• PAP 22 applies to regular paper products, including bags, wrapping paper, magazines, and printed materials.

Using the correct code ensures that your packaging is sorted and recycled, particularly in automated waste management systems.

At an EU level, the material identification system is described as voluntary. However, individual member states can introduce their own requirements, and some have made these markings compulsory.

Italy and Bulgaria are notable examples. Italy introduced Legislative Decree No. 116 in September 2020, which made material identification markings mandatory effective 1 January 2022.

This means that any packaging that is supplied into Italy must display the appropriate material codes, including PAP 20 for corrugated cardboard.

For businesses exporting into these countries, compliance is essential, even where marking is not legally required. Applying PAP 20 voluntarily carries responsibilities, as it signals that your packaging complies with the essential requirements of the Packaging Directive.

Responsibility for using the correct recycling symbols lies with the business placing the packaged goods on the market. This includes ensuring that the symbol accurately reflects the material used.

This distinction is essential. If you apply PAP 20 to packaging that is not fully recyclable, such as corrugated fibreboard, you may be providing misleading information and could fall foul of local regulations.

There are also practical differences in how recycling symbols are applied depending on whether the packaging is intended for consumers or businesses.

For B2C packaging, including eCommerce shipments, the PAP 20 logo should be printed directly onto the packaging wherever possible. Only in limited circumstances is it acceptable to include this information in accompanying documentation, such as instruction leaflets.

For B2B packaging, many countries allow material identification to be provided via the shipping documents rather than printed directly on the packaging itself. However, best practice remains to clearly mark the packaging, mainly where goods may be redistributed or reused.

If you need to add PAP 20 markings to your corrugated packaging, there are several practical options.

Printing the symbol directly onto the packaging is the most common and visually consistent approach, although it may require changes to print plates or artwork. Perforated markings are another option, but can involve tooling changes.

Alternatively, labels can be applied to existing packaging. This approach is often used by businesses supplying multiple regions with different regulatory requirements, as it allows the same packaging to be used across markets while remaining compliant.

Not all paper-based packaging is recyclable; in such cases, PAP 20 should not be used.

Packaging that combines fibreboard with plastic or aluminium layers, such as drinks cartons or certain food packaging, can’t be recycled in the same way as corrugated cardboard. These materials require different identification codes.

For mixed paper and plastic materials, the C/PAP 84 symbol is used. Laminated cardstock products, such as greeting cards or printed promotional materials, typically fall under the CSL 87 code. Using the correct symbol ensures waste is handled appropriately and avoids confusion for recycling operators.

In some regions, such as Italy, applying the PAP 20 logo to corrugated packaging is a legal requirement. In others, it remains voluntary but strongly encouraged.

Beyond compliance, there are clear business benefits. Customers and commercial partners increasingly expect packaging to be clearly labelled and recyclable. Providing clear recycling information improves customer experience, supports sustainability goals, and may even influence purchasing decisions.

As a result, even where it is not mandatory, using PAP 20 on corrugated packaging is generally considered best practice.

If you are unsure whether your packaging should display the PAP 20 logo or another material identification code, at Suttons, we can help you navigate the requirements and ensure your packaging is both compliant and fit for purpose.

Get in touch with our team of experts today.