What is PAP 22? The paper recycling code explained

You will find "PAP 22" printed under a small recycling arrow on paper bags, flow-packs and tea envelopes, and you will see it in supplier spec sheets as a selling point. It is one of the most searched packaging terms we see, and one of the least explained. This guide covers what the code means, when a coated or heat-sealable paper can still carry it, and what it does and does not prove.

Where the code comes from

The numbers come from Commission Decision 97/129/EC, which set up a voluntary identification system for packaging materials across the EU. Each material family has its own abbreviation and number range: plastics 1–19, paper and board 20–39, metals 40–49, wood 50–59, textiles 60–69, glass 70–79 and composites 80 and above.

The difference that matters is the one between PAP 22 and the C/PAP codes. A paper/PE laminate looks like paper on the shelf, but it is a composite: the layers cannot be separated by hand, and in many recycling systems it is treated, and charged, differently from paper.

When can a coated paper still be PAP 22?

Almost no functional paper pack is pure fibre. It carries a barrier coating to stop grease or moisture, a heat-seal layer so it can close on a packing line, printing inks and sometimes a window. So the real question is how much of that is allowed before paper stops being paper.

The EU Packaging and Packaging Waste Regulation (PPWR) answers this in its definition of composite packaging. A pack made of two or more materials that cannot be separated by hand is a composite, unless the other material is an insignificant part of the pack and in any case no more than 5% of its total mass. Labels, varnishes, paints, inks, adhesives and lacquers are left out of that calculation.

In practice, this is why heat-sealable barrier papers are engineered with very thin coatings. Our current PURESEAL HS 70 platform runs at about 2.5 g/m² of barrier coating on a 70 g/m² base paper, which keeps it well inside the line.

Check your own structure

Enter the grammages from your spec sheet. The calculator counts everything that is not fibre, including inks and coatings, so it is stricter than the legal definition. If you pass here, you are comfortably inside the 5% line.

A plastic window is the most common reason a paper pack falls out of PAP 22. A window film is a separate material, so it counts. A window made from transparent cellulose, as in our kraft flow-pack with a crystal window, keeps the pack fibre-based.

The code is a claim, not a proof

Printing PAP 22 on a pack tells the consumer which bin to use. It does not prove that the pack actually recycles well. That is measured separately, in a laboratory, by pulping the material the way a paper mill would and checking how much fibre comes back and how clean it is.

In Europe the reference method is the 4evergreen fibre-based packaging recyclability protocol, tested by institutes such as PTS in Heidenau. The result is a score out of 100. Our own heat-sealable barrier paper went from 68 in 2023 to 99 unprinted and 94 printed in 2026; we wrote up the full journey here.

When a supplier tells you a material is PAP 22, ask for the test certificate behind it. The code and the score answer different questions, and you need both.

Why PAP 22 matters for cost and compliance

• EPR fees. Producer responsibility fees are charged per kilogram and per material. In most national schemes, paper sits in a lower fee band than plastics and composites, so moving a pack from C/PAP to PAP 22 can lower the fee on every unit you place on the market.
• PPWR recyclability grades. From 2030, packaging must reach at least grade C for recyclability, and from 2038 at least grade B. A well-designed PAP 22 pack is built for the top grades.
• Single-use plastic bans. From 2030 the PPWR restricts certain single-use plastic formats. Under the same composite definition, a paper-based pack with more than 5% plastic counts as composite packaging, not paper. The 5% line does not exempt a partly plastic single-use pack from the Single-Use Plastics Directive, so check coated formats against those rules too.
• Labelling. The 97/129 codes are voluntary in most countries, though some, such as Italy, require material identification on packaging. Harmonised EU sorting labels follow under the PPWR, from August 2028 at the earliest.

Where PAP 22 works, and where it does not

Paper is not the right answer for every product, and a good supplier will tell you when it is not. Today's water-based barrier papers are excellent at grease, aroma and heat-sealing, and less strong on oxygen and moisture.

Is PAP 22 plastic-free?

Not necessarily. Barrier and heat-seal coatings are thin polymer dispersions, so a PAP 22 pack can contain a few percent of non-fibre material. What PAP 22 tells you is that the pack is paper by design, behaves as paper in the recycling stream and contains no separate plastic layer. If you need to make a "plastic-free" claim on pack, check it against the exact structure and the rules in each market before printing.

What to ask your supplier

• The composition by weight: base paper, coatings, inks and any window or other layer.
• A recyclability test certificate for that exact structure, printed if possible.
• The EU Declaration of Conformity and food-contact documentation.
• Total fluorine data, to show the barrier is PFAS-free.
• A sample roll, so you can confirm it runs on your machine before you commit.

We make PAP 22 flow-pack paper, tea envelopes and paper bags in Vilnius, and coat paper for other converters. Send us your current structure and we will tell you whether a PAP 22 version is realistic for your product, and if it is not, we will tell you that too.