The legislative framework
Paper and packaging produced in or imported into the European Union must comply with a layered set of legislative requirements. At the product level, Directive 94/62/EC on packaging and packaging waste is the central instrument. At the production level, the Industrial Emissions Directive (IED, 2010/75/EU) governs how mills operate and what they can discharge. Overlapping these are specific technical standards for particular applications — notably ISO 9706 for archive-quality paper.
Directive 94/62/EC — packaging and packaging waste
Adopted in 1994 and amended several times since, Directive 94/62/EC established the framework for managing packaging placed on the EU internal market. It applies to all packaging — paper, board, plastic, glass, metal — and sets requirements under four main headings.
Heavy metal concentration limits
The directive sets a combined concentration limit of 100 ppm for lead, cadmium, mercury, and hexavalent chromium in packaging material. This applies to the packaging itself, not its contents. Paper and board packaging must be manufactured with inks, coatings, and adhesives that comply with this limit. Some derogations exist for recycled materials where contamination from prior use is difficult to avoid entirely, but these are tightly controlled.
Recoverability requirements
All packaging must be recoverable through one of four routes:
- Material recycling — the packaging can be reprocessed into new material
- Energy recovery — the packaging can be incinerated with energy capture
- Composting — the packaging degrades under controlled composting conditions to a standard enabling use in soil improvement
- Biodegradation — the packaging degrades in a landfill or natural environment within specified timeframes
Paper and board packaging readily satisfies the material recycling and energy recovery routes. Compostable paper packaging must meet EN 13432, which specifies disintegration, ecotoxicity, and biodegradation thresholds.
Recycled content targets
Amendments to the directive — including those proposed under the Packaging and Packaging Waste Regulation (PPWR) under discussion as of 2026 — introduce minimum recycled content requirements for packaging placed on the EU market. Paper and board are generally well-positioned relative to these targets given existing recycling infrastructure, but mills producing paperboard for food contact must also comply with food-safety restrictions on recycled fibre under Regulation (EC) 1935/2004 and associated national guidance.
Design for recyclability
The directive and its implementing measures require that packaging be designed so that it can be sorted and recycled efficiently. For paper packaging, this creates constraints on barrier coatings, adhesive labels, and lamination constructions — all of which can interfere with mill repulpability. Industry associations including CEPI and the European Paper Packaging Alliance publish repulpability assessment protocols used by mills and converters when evaluating new packaging constructions.
BREF documents and BAT conclusions
The Industrial Emissions Directive requires that large combustion plants, chemical producers, and industrial operators — including paper mills above defined capacity thresholds — hold a permit based on Best Available Techniques (BAT). The technical substance of BAT is defined in BREF (BAT Reference) documents prepared by the European IPPC Bureau at the Joint Research Centre in Seville.
The BREF for the pulp and paper sector was most recently revised in 2015. It sets BAT-Associated Emission Levels (BAT-AELs) for:
- Chemical oxygen demand (COD) and biological oxygen demand (BOD) in liquid effluent
- Suspended solids in effluent
- Total reduced sulphur (TRS) from kraft mills
- Sulphur dioxide and nitrogen oxides from energy generation
- Particulate matter from recovery boilers and lime kilns
National permit authorities must set emission limits at or below BAT-AEL values. Mills operating significantly above these levels are required to upgrade. Permit reviews are triggered when BREF documents are updated.
BREF documents are not directly binding legislation, but once adopted as BAT conclusions via a Commission Implementing Decision, permit conditions must reflect their emission levels within four years of publication.
ISO 9706 — permanence for paper in documents and publications
ISO 9706 specifies requirements for paper intended to last for long periods — generally defined as several hundred years under normal library storage conditions. The standard is relevant to mills producing paper for book printing, archival documents, and government records.
Key requirements under ISO 9706 include:
- pH in cold water extract: 7.5 minimum
- Alkaline reserve (CaCO3 equivalent): at least 2% by mass
- Kappa number: 5 or less (indicating low residual lignin)
- Tear resistance (Elmendorf method): minimum depending on grammage
Mills producing permanent paper must control the chemical composition of their product carefully, avoiding the use of acid sizing agents such as alum-rosin which cause long-term degradation. Alkaline sizing with alkyl ketene dimer (AKD) or alkenyl succinic anhydride (ASA) is standard in permanent-paper grades.
Food contact compliance
Paper and board intended for food contact — including food service boards, bakery bags, and freezer paper — must comply with Regulation (EC) 1935/2004 on materials and articles in contact with food. A harmonised EU positive list for paper and board is not yet in place as of 2026; in its absence, mills and converters rely on national frameworks (notably the German BfR recommendations and the Dutch NVWA guidance) and industry self-regulation through the CEPI/FEICA joint approach.
Recycled fibre in food contact paper is subject to particular scrutiny because recovered paper may contain mineral oil hydrocarbons (MOSH/MOAH) from printing inks. German and Swiss authorities have issued guidance on limits; EU-level regulation on mineral oils in food contact materials was under development as of 2026.
National transposition and enforcement
Directives are transposed into national law by each member state. In practice this means German, French, and Swedish paper sectors operate under national permit systems that implement IED requirements, administered by national or regional environmental agencies. The approaches can differ at the margins — particularly around monitoring frequency and reporting requirements — while the underlying emission limits are constrained by BAT-AEL values.