FR 
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RU Many brands assume that using recycled fibre in paper packaging is enough to demonstrate environmental compliance. In practice, recycled content claims, material traceability, and regulatory documentation serve different purposes.
For brands sourcing paper bags, food packaging, and retail packaging for the European market, understanding these differences is becoming increasingly important.
The EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40, began applying on August 12, 2026. It establishes a broader framework for packaging sustainability, recyclability, waste reduction, and producer responsibilities. Businesses must assess the requirements applicable to their packaging rather than relying on a single environmental label or supplier declaration.
Two important areas to review are FSC Chain of Custody (CoC) certification et post-consumer recycled (PCR) content verification. Although they address different questions, together they can help buyers build a more complete packaging documentation process.
1. What Does PPWR Compliance Mean for Paper Packaging?
PPWR is not simply a requirement to use environmentally friendly materials. It introduces requirements covering packaging design, recyclability, substances of concern, recycled content in specified packaging categories, and other aspects of the packaging life cycle.
The precise obligations depend on the packaging type, material composition, intended use, and applicable implementation timeline.
For paper bags and food packaging, procurement teams should review several questions:
- What materials and coatings are used in the packaging?
- Can the packaging be collected, sorted, and recycled under the applicable requirements?
- Are recycled-content claims supported by reliable evidence?
- Can the supplier provide material specifications and traceability records?
- Are food-contact safety and other relevant requirements addressed?
It is important to distinguish legal requirements from voluntary certification schemes and customer-specific purchasing standards. PPWR does not impose a universal 65% PCR threshold on all paper bags or a universal 70% threshold on all gift boxes. Nor does it require every paper packaging product to hold FSC or PEFC certification.
Buyers should therefore confirm the requirements that actually apply to their products and destination markets before specifying a material or certification target.
2. FSC Chain of Custody: Understanding Material Traceability
The Forest Stewardship Council (FSC) operates a certification system intended to support responsible sourcing and the traceability of forest-based materials through the supply chain.
For packaging buyers, FSC Chain of Custody certification helps establish whether an organization can handle and document materials in accordance with the applicable FSC standard.
When evaluating a paper packaging supplier, check the following:
- Whether the FSC certificate is valid and can be verified.
- Whether the certified company, production site, and product scope are relevant to your order.
- Whether purchase and sales documents support the applicable FSC claims.
- Whether transaction records and material accounting records are maintained.
- Whether the finished packaging can legitimately carry the intended FSC claim.
An FSC logo alone is not sufficient evidence that every product supplied by a factory is FSC-certified. The relevant certificate scope, product claims, and transaction documents must be checked.
Under the FSC Chain of Custody standard, organizations are required to maintain relevant conformity records for at least five years. These records support traceability and help demonstrate that the certified-material claims are properly managed.
For procurement teams, this means certification should be reviewed alongside the actual documents associated with the order.
3. PCR Content Verification: What Buyers Should Request
Post-consumer recycled (PCR) fibre comes from paper products that have been used by consumers and recovered for recycling. It is different from pre-consumer recycled material, which generally originates from manufacturing or processing waste before reaching consumers.
When a supplier claims that a paper bag contains a particular percentage of PCR fibre, buyers should establish how that figure was calculated and what evidence supports it.
A useful PCR verification file may include:
| Document or information | What it helps verify |
|---|---|
| Recycled-content declaration | The claimed percentage of recycled fibre |
| Material specification | Fibre composition and relevant paper grades |
| Supplier or mill documentation | The declared source and type of recycled pulp |
| Batch or production records | The relationship between materials used and the finished production lot |
| Quality test reports | Relevant physical performance and product specifications |
| Food-contact documentation, where applicable | Compliance with applicable food-contact requirements |
The calculation method should be clearly defined. If recycled content is expressed by weight, the supplier should identify the denominator, the material included in the calculation, and whether the percentage applies to the paper substrate or the entire packaging product.
A recycled-content declaration should not be confused with independent verification. Depending on the buyer’s requirements, additional evidence or third-party assessment may be appropriate.
4. Why High PCR Content Requires Performance Testing
Increasing the proportion of recycled fibre can affect paper properties. The actual impact depends on fibre quality, the paper-making process, the packaging structure, and the intended application.
For paper bags, buyers may need to evaluate tensile strength, tear resistance, handle attachment, and load-bearing performance. For food packaging, print quality, barrier performance, odour, and applicable food-contact safety requirements may also matter.
The objective is not simply to maximize recycled content. It is to select a material composition that meets the buyer’s sustainability objectives while maintaining the required packaging performance.
Before approving a new paper grade, buyers should consider requesting samples, reviewing technical specifications, and conducting application-specific testing.
This is especially important for packaging used in food service, supermarket delivery, retail distribution, and other applications where the package must withstand handling and transport.
5. How FSC Certification and PCR Documentation Work Together
FSC CoC certification and PCR content verification answer different questions.
FSC CoC concerns the traceability and control of materials covered by the applicable FSC certification system. PCR documentation supports claims about the proportion and source of recycled material.
Neither automatically substitutes for the other. A valid FSC certificate does not, by itself, prove a specific PCR percentage. Likewise, a recycled-content declaration does not establish that a product qualifies to carry an FSC claim.
For procurement teams, the practical solution is to maintain a coordinated documentation file for each relevant packaging product or order.
A supplier review can follow this sequence:
- Confirm the applicable requirements. Identify the destination market, packaging category, intended use, and relevant legal or customer requirements.
- Verify certification scope. Check the supplier’s FSC CoC certificate and confirm that the relevant company, site, and product claims are covered.
- Review recycled-content evidence. Request a clear PCR declaration and supporting material information.
- Match records to production. Where available and relevant, link material records, purchase documents, and production batches to the finished packaging.
- Check product performance. Confirm that the packaging meets the required strength, printing, barrier, and food-contact specifications.
- Complete the compliance review. Identify any remaining gaps before approving production or shipment.
This approach helps buyers distinguish between a supplier’s general sustainability claims and evidence that is specific to the packaging they intend to purchase.
6. How Nanwang Supports Paper Packaging Buyers
Fujian Nanwang Environment Protection Scien-tech Co., Ltd. (Stock Code: 301355) manufactures paper packaging for retail and food-service applications.
According to company information, five of Nanwang’s domestic factories held FSC-COC certification by the end of 2025. The company also reported using 21,000 tonnes of FSC-certified base paper and 14,000 tonnes of regenerated kraft paper during 2025.
These figures provide context for the company’s material sourcing and manufacturing operations. Buyers should still confirm the relevant certificate scope, material specifications, and supporting records for their particular products and orders.
For brands evaluating paper bags and food packaging, the most useful next step is to discuss requirements at the product level. This may include paper grade, recycled-fibre targets, packaging performance, printing, food-contact requirements, and the documentation needed for internal compliance review.
The right documentation package depends on the product and the claims being made. It should be specific enough for procurement, quality, and compliance teams to review consistently.
7. Paper Packaging Compliance Checklist for Buyers
Before confirming an order, ask your supplier:
- Can you provide a valid FSC CoC certificate and confirm the applicable product and factory scope?
- What percentage of the paper fibre is post-consumer recycled, and how is that percentage calculated?
- Can you provide supporting material declarations and relevant production records?
- Are the packaging specifications and performance test results available?
- For food packaging, can you provide the relevant food-contact compliance documentation?
- Which requirements are legal obligations, which are voluntary certifications, and which are customer-specific specifications?
A supplier’s ability to answer these questions clearly can make material evaluation and purchasing decisions more efficient.
Looking for a paper packaging supplier that can support your material and documentation requirements?
Visit Nanwang Paper Packaging to explore paper bags and food packaging solutions, or contact the Nanwang team to discuss your product specifications, recycled-fibre requirements, and certification documentation.