PENTAROM SRL – Packaging compliance with the PPWR

The company's declaration covers the cardboard and wooden packaging families defined in the document, including boxes, dividers, kits, pressed cardboard corner protectors/protective elements, cardboard tubes, type II corrugated cardboard, pallets, crates/boxes, wooden elements, beams, slats and compressed sawdust components used in packaging structures. Auxiliary components are included only if they form part of the packaging unit and are identified in the technical documentation.

The declaration does not replace the technical file for each type of packaging and does not mean that every product, material, supplier or batch has been individually tested. Conclusions must be considered together with the drawing, product code, bill of materials (BOM), intended use and documents specific to the product delivered.

The main legislative reference is Regulation (EU) 2025/40 on packaging and packaging waste (PPWR), applicable from 12 August 2026, together with the relevant delegated/implementing acts and European Commission guidance.

Article 5: requirements for substances in packaging, including the limit for the sum of Pb + Cd + Hg + Cr(VI) and the PFAS requirements for packaging intended to come into contact with food.

Article 6: recyclability requirements, with harmonised criteria and specific implementation stages.

Article 10: minimisation of packaging weight and volume without compromising functionality.

Article 12: labelling, marking and information requirements, including harmonised requirements introduced in stages.

Article 15: manufacturer obligations, packaging identification, manufacturer identification, conformity assessment and retention of documentation.

Articles 38–39 and Annexes VII–VIII: conformity assessment, technical documentation and the EU declaration of conformity, as applicable.

PENTAROM maintains the technical documentation for its products and reassesses conformity when relevant changes are made to the design, materials, suppliers, manufacturing process, intended use or legislative requirements. The documentation and EU declaration of conformity are retained for the period required by the PPWR: 5 years for single-use packaging and 10 years for reusable packaging.

Article 5(4) of the PPWR stipulates that the sum of the concentrations of lead (Pb), cadmium (Cd), mercury (Hg) and hexavalent chromium [Cr(VI)] in packaging or packaging components must not exceed 100 mg/kg (100 ppm), subject to the applicable legal conditions and exceptions.

PENTAROM's documentary analysis report BA-PPWR-HM-160926, dated 16.09.2026, summarises reports for paper samples used in cardboard production. For reports 768739/25/INT, 768740/25/INT and 768741/25/INT, the sum of heavy metals is reported as 11.2 ± 2.2 mg/kg, 10.6 ± 2.1 mg/kg and 10.4 ± 2.1 mg/kg respectively; the reports indicate PASS against the 100 mg/kg criterion.

According to the company's documentation, the industrial packaging manufactured by PENTAROM is not intended for direct contact with food. The specific PFAS requirements in Article 5(5) must be assessed according to the actual intended use of the packaging, particularly for packaging intended to come into contact with food.

PENTAROM report BA-PPWR-PFAS-160926, dated 16.09.2026, summarises TF/TOF evidence for two paper/cardboard grades: WELLENSTOFF HIGH PERFORMANCE, with TF 42 ± 7 mg/kg and TOF <20 mg/kg, and TESTLINER, with TF 49 ± 8 mg/kg and TOF <20 mg/kg. The results are reported as PASS against the 50 mg/kg screening criterion used in the reports.

Important limitation: these are TF/TOF screening results and do not constitute a targeted analysis to identify and quantify each individual PFAS. For packaging intended to come into contact with food, these results do not automatically replace targeted PFAS analyses or any additional documents that may be required. The reported uncertainties must be taken into account, particularly for TESTLINER (49 ± 8 mg/kg).

PENTAROM designs cardboard and wooden packaging so that, under the intended conditions of use and with appropriate separation of incompatible components, it can be directed to the relevant collection, sorting, recycling and/or recovery streams.

Paper and corrugated cardboard are intended for paper/cardboard collection and recycling streams, depending on local infrastructure and the condition of the material.

Wooden packaging can, as appropriate, be directed to reuse, repair, collection and recycling/recovery through dedicated wood streams.

For composite packaging or mixed kits (for example, a wooden pallet + a cardboard box), the components must be identified and separated where possible and appropriate.

Adhesives, metal/plastic elements and other auxiliary components may affect end-of-life management and must be assessed according to the product's construction.

Recyclability must be assessed in accordance with the harmonised criteria applicable to the packaging category and the implementation stages set out in the PPWR. Actual recyclability also depends on the available infrastructure, contamination, component separation and local collection practices.

PENTAROM declares that packaging design takes into account reducing weight and volume to the minimum necessary to protect the product and meet functional, production, handling, storage and transport requirements.

Packaging is described as reusable only when its design, intended use and operational system support this characteristic under the conditions of the PPWR.

PEFC / FSC certification

PENTAROM SRL holds international FSC® Chain of Custody and PEFC Chain of Custody certifications, which attest to the responsible management and traceability of raw materials from controlled and sustainable forest sources. The certifications cover both cardboard and wooden packaging manufactured by our company.

REACH Declaration

This declaration confirms the company's position that its products comply with the relevant requirements of REACH Regulation (EC) No. 1907/2006 and states that the finished products do not contain SVHC substances above the thresholds specified in the legislation.

*FSC, PEFC and REACH are relevant elements of the control and procurement system.

To ensure traceability, each packaging type/family must be linked, as appropriate, to a product code, drawing or customer reference, bill of materials (BOM), suppliers and material grades, batch/serial number and the relevant control documents. Where the size or nature of the packaging does not allow direct marking, identification information must be managed in a manner permitted by the PPWR, including accompanying documentation where applicable.

Technical documentation may include the description and intended use, drawings, BOM, specifications, substance and recyclability assessments, test reports, supplier declarations and evidence of process control.

The general product family declaration must not be used to support conclusions beyond its documented scope.

Changes to the supplier, cardboard grade, adhesive formulation, treatment, components, design or intended use must be assessed to determine whether new documents or tests are required.

For wooden packaging subject to phytosanitary export requirements, the ISPM 15 marking and applicable documents remain separate from PPWR information and are not replaced by the QR code.

The QR code is applied to the label at the customer's request. PENTAROM's role is to facilitate access to public information on the manufacturer, packaging family, materials, available compliance documentation and end-of-life management guidance. The QR code does not itself constitute certification and does not replace conformity assessment, the EU declaration of conformity where applicable, technical documentation, mandatory markings or customer-specific requirements.

Identification of the manufacturer and the packaging must comply with Article 15(5)–(7) of the PPWR. Harmonised labels concerning material composition, sorting, reuse or other information under Article 12 are implemented in accordance with the relevant implementing acts and legal deadlines. The PENTAROM identification label presented here must not be confused with an official harmonised label.

For enquiries about a product's compliance documentation, technical specifications or its connection with an order/delivery, contact PENTAROM SRL via www.pentarom92.ro, calitate@pentarom92.ro or contact@pentarom92.ro. Please include the product code and customer reference.