The cardboard exemption and what it means for moisture

The EU Packaging and Packaging Waste Regulation (PPWR) is reshaping how transport packaging is designed, used, and discarded across the European Union. Among its most consequential provisions is Article 29, which establishes binding reuse targets for transport packaging. Yet one widely used format sits outside these obligations: the humble cardboard box.

For logistics and packaging managers weighing reusable packaging vs cardboard, this exemption introduces a strategic question that extends beyond compliance into material performance, supply chain resilience, and moisture exposure during transit.

Understanding the PPWR cardboard exemption

Under PPWR Article 29, transport packaging used between economic operators must meet a 40 % reuse target by 2030, rising to 70 percent by 2040. These PPWR reuse targets transport packaging across pallets, crates, boxes, and similar B2B logistics formats. However, packaging made predominantly of paper or cardboard is exempt.

The reasoning rests on the recyclability profile of fibre-based materials, which already enjoy high collection and recycling rates across Europe. From a regulatory standpoint, cardboard is treated as a circular material by default.

For packaging managers, the implication is significant. Companies adopting reusable plastic transport packaging must invest in tracking systems, return logistics, cleaning, and pooling arrangements. Continuing with cardboard avoids this operational complexity.

Based on currently available information, this asymmetry may accelerate a shift toward, or continued reliance on, single-use cardboard formats among organisations seeking the path of least regulatory resistance.

The push toward higher recycled fibre content

While Article 29 exempts cardboard from reuse targets, other parts of the PPWR framework apply pressure in a different direction. Design for Recycling (DfR) requirements and broader sustainability commitments encourage manufacturers to increase recycled fibre content in corrugated packaging. The intent is sound: closing the fibre loop reduces virgin pulp demand and lowers environmental footprint.

The trade-off is technical. Each time cellulose fibres pass through recycling, they shorten. According to analysis of recycled fibre durability, shorter fibres bond less effectively, reducing tensile strength, stacking performance, and dimensional stability. Recycled cardboard moisture behaviour also shifts: shorter fibres tend to absorb more atmospheric humidity, further degrading mechanical performance.

Research on humidity effects in recycled corrugated board confirms that compressive strength can decline measurably as relative humidity rises, with recycled content amplifying the effect. In transit through fluctuating climate zones, this can translate into collapsed stacks, damaged primary packaging, and compromised goods on arrival.

Why origin and imported cardboard quality matter

A second variable is often overlooked in procurement: where the cardboard comes from. Imported cardboard quality EU buyers receive can vary considerably by source region.

Based on Absortech’s operational experience, European-produced cardboard, such as Swedish kraft-based board, typically demonstrates stronger, more consistent fibre length and more predictable moisture behaviour.

Cardboard sourced from certain Asian markets, while often meeting basic specifications, can show greater variability in fibre quality and recycled content.

For EU importers receiving finished goods packaged at origin, the cardboard protecting incoming shipments may already carry a different moisture-performance profile than equivalent European board. Combined with rising recycled fibre content across the global supply base, this creates greater variability in how packaging behaves under humid transit conditions.

The moisture dimension in the reusable packaging vs cardboard decision

Moisture is not a niche concern. Shipping containers crossing oceans routinely encounter condensation cycles driven by temperature differentials between day and night, and between climate zones. Longer voyages pass through multiple climate zones, compounding moisture risk beyond simple duration.

The climate at loading also affects the air sealed inside the containment unit and the moisture already absorbed by goods and packaging materials prior to loading. Loading utilisation, meaning the free air space inside the unit, further influences how the box breathes and how moisture redistributes during transit.

Cardboard, being hygroscopic, participates actively in this dynamic. Higher recycled content increases its moisture uptake, and uptake reduces compressive strength precisely when stacking loads are highest. Choosing cardboard to sidestep PPWR reuse obligations is therefore not a neutral decision from a product-protection standpoint.

Factors worth evaluating

• Recycled fibre percentage in the corrugated board used for export packaging.
• Origin of the cardboard supply and consistency of incoming specifications.
• Typical route profile, including climate zones traversed and voyage duration.
• Stacking configuration and loading utilisation within the containment unit.
• Existing moisture protection measures, such as high-performing CaCl2 desiccants, and whether dimensioning still matches the new material profile.

These are key variables, not an exhaustive list, but they capture the core of the trade-off.

Where desiccants fit, and an open interpretive question

Tailored protection through precision-engineered desiccants has long served as a comprehensive prevention strategy for hygroscopic packaging in international freight. High-performing CaCl₂ desiccants offer up to 150% moisture absorption capacity per unit weight for dimensioning purposes, significantly greater than low-performing silica gel and clay alternatives, which is relevant where packaging minimisation and weight reduction are also regulatory priorities.

That said, how desiccants and other protective inserts are classified under the PPWR framework remains an open question. The current interpretation is that classification will be clarified through subsequent delegated and implementing acts, which typically come into force two years after release.

Until then, packaging teams should treat moisture protection planning as a parallel workstream to PPWR compliance.

Conclusion: a balanced view for packaging managers

The PPWR cardboard exemption offers a legitimate route to avoid the complexity of reuse infrastructure. But the exemption does not eliminate the technical realities of fibre-based packaging in humid transit, and the parallel pressure toward higher recycled content makes those realities more pronounced. Variability in imported cardboard quality EU importers experience adds another layer of consideration.

Logistics and packaging managers benefit from evaluating material choice and moisture exposure together, rather than in isolation. Absortech’s expert guidance supports this evaluation, helping organisations understand how their packaging portfolio behaves across routes, climates, and supplier sources.

To discuss how these dynamics apply to a specific supply chain, the Absortech team is available through the contact form, and ongoing analysis is shared through the Absortech newsletter.