Due to the use of recycled fibers, packaging may contain some of the substances listed in Safe Drinking Water and Toxic Enforcement Act of 1986 of the State of California also known as California Prop 65 list as impurities. Please note that we have not made any further assessments on these substances. It should be noted that California Prop 65 is only applicable for the products put on a market in the US California.
Persistent Organic Pollutants
We certify that none of the persistent organic pollutants (POPs) listed under the Stockholm Convention or in the amended Regulation (EU) 2019/1021 on POPs are deliberately incorporated into our products during production. “Deliberately incorporated” means a substance is used in a material or component formulation specifically so that it remains in the finished product to give it a certain property, appearance or quality. Please note that we do not routinely test our products for these substances.
At the date of signing of this document, our products do not contain substances included on the REACH Candidate List of Substances of Very High Concern (SVHC) in a concentration above 0.1% (w/w).
Our products do not contain substances that require authorization under REACH Annex XIV, or substances included in Annex XVII (Restrictions), where the restriction is applicable to our use.
Directive 2011/65/EU, as amended (the so-called “RoHS Directive”), concerning the restriction of the use of certain hazardous substances in electrical and electronic equipment, is not applicable to our products.
Based on our current knowledge, and information provided by our material suppliers, the substances listed in Annex II — namely polybrominated biphenyls (PBB), polybrominated diphenyl ethers (PBDE), bis(2-ethylhexyl) phthalate (DEHP), butyl benzyl phthalate (BBP), dibutyl phthalate (DBP), and diisobutyl phthalate (DIBP) — are not intentionally added* to the raw materials used in our manufacturing processes.
* Intentionally added refers to substances deliberately used in the formulation of a material or component, where their continued presence in the final product is intended to provide a specific characteristic, appearance, or quality. Please note that this statement is based on information received from our material suppliers, and we do not routinely perform analytical testing for these substances. It should also be noted that trace amounts of these substances may be present in corrugated board and packaging as impurities due to the use of recycled fibres.
We hereby confirm that products supplied by Pakkauspojat Oy do not conflict with the above-mentioned legislation.
Our corrugated board products do not contain any of the following substances:
Under the Waste Framework Directive (2008/98/EC, amended by Directive (EU) 2018/851), articles containing SVHC substances above 0.1% (w/w) must be notified to ECHA’s SCIP database. Based on our current knowledge and information provided by our material suppliers, our products do not contain SVHC substances above this threshold and no SCIP notification obligation applies.
This declaration certifies that, based on our current knowledge and on information provided by our material suppliers, the corrugated cardboard products supplied by Pakkauspojat Oy do not contain any of the Persistent, Bioaccumulative, and Toxic (PBT) substances listed below as intentionally added in the manufacturing of the raw materials, as restricted under Title 40 of the Code of Federal Regulations, Part 751 – “Regulation of Certain Chemical Substances and Mixtures under Section 6 of the Toxic Substances Control Act (TSCA)”.
List of substances: Phenol, Isopropylated phosphate (3:1) (PIP (3:1)), Decabromodiphenyl ether (DecaBDE), 2,4,6-Tris(tertbutyl)phenol (2,4,6-TTBP), Hexachlorobutadiene (HCBD), Pentachlorothiophenol (PCTP)
Products produced by Pakkauspojat Oy, comply with relevant applicable European legislation. Conflict minerals (Tantalum, Tin, Gold, Tungsten) are not intentionally added in our cardboard products or materials. Conflict minerals are not needed in the production of our products or materials.
Pakkauspojat Oy certifies that all corrugated cardboard products manufactured by us, as well as the materials used in our production, are sourced from Finland or within the European Union.
Pakkauspojat Oy is committed to providing customers with high-quality and environmentally friendly corrugated cardboard products with a reliably traceable origin. All corrugated cardboard materials used in our production processes meet stringent environmental and quality standards, ensuring a safe and sustainable supply chain.
Between 75-90% of the corrugated cardboard materials we use are sourced from Finland, while the remainder comes from within the European Union. The majority of our products are manufactured at our production facility in Finland, with the rest produced by our partners within the EU. These externally produced items are primarily certain types of cardboard that have limited availability in Finland. This supports the local economy and shortens supply chains, ensuring high quality and reliability.
Pakkauspojat Oy is proud to offer fully domestic corrugated cardboard products, giving our customers the opportunity to choose a responsible and sustainable packaging solution.
This declaration is valid unless otherwise stated.
Adsorbable Organic Halogen Compounds (AOX) consist of organic molecules that contain halogens—chiefly chlorine, bromine and iodine—and which can be captured on activated carbon. AOX is reported as a single, aggregate value (in µg/L expressed as chloride equivalents) that represents the total load of these halogenated organics in a sample. Because many AOX substances are resistant to breakdown and can accumulate through the food web, they may pose long-lasting ecological and health risks.
In the materials supplied by our material suppliers for corrugated-board production, no substances are used that would generate AOX emissions. The vast majority of fibres supplied by our material suppliers are unbleached; any bleached fibres they provide may carry an AOX burden. To keep the environmental impact to a minimum, our material suppliers exclusively employ Elemental Chlorine Free (ECF) bleaching in producing the fibres they deliver—an approach that drastically curtails the formation of toxic by-products compared with conventional chlorine bleaching.
Pakkauspojat Oy is a manufacturer of corrugated and paper-based packaging products. We do not harvest timber and we do not place primary wood-based raw materials on the market.
We acknowledge the requirements of Regulation (EU) 2023/1115 on deforestation-free products (EUDR) and are preparing our internal processes accordingly.
Our compliance approach is based on the following principles:
As a downstream converter, our role is to ensure that the materials used in our products originate from suppliers that have implemented appropriate due diligence systems in line with the EUDR.
This statement reflects our current understanding of the Regulation and will be reviewed and updated as regulatory requirements and implementation practices evolve.
This compliance statement covers corrugated board packaging and corrugated board material supplied by Pakkauspojat Oy. The statement will be updated once the relevant secondary legislation is adopted and enters into force.
Pakkauspojat Oy is committed to compliance with the EU Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40), which applies from 12 August 2026. According to the regulation, for packaging where the design specification is provided by the customer, Pakkauspojat Oy acts as a supplier. For packaging designed and manufactured to customer specifications, the customer is considered the manufacturer. For off-the-shelf products with a predefined design specification and product number, Pakkauspojat Oy is considered the manufacturer.
As a supplier of corrugated board packaging and packaging material, Pakkauspojat Oy is committed to providing manufacturers with all information required to carry out conformity assessment and prepare the EU PPWR Declaration of Conformity (PPWR DoC) in accordance with Articles 38–39 and Annexes VII–VIII.
1. General Description and Intended Use
Pakkauspojat Oy manufactures and supplies corrugated board packaging and corrugated board material. Products are used for packing, supporting and/or protecting goods. The product range covers two main material categories described in Sections 2 and 3 below.
2. Standard Corrugated Board (Fiber-Based, No Plastics)
This section covers the majority of products supplied by Pakkauspojat Oy.
Material composition:
Article 5 – Substance Requirements
Heavy metals (Article 5(4))
On the basis of information from our raw material suppliers and our own production knowledge, our products meet the requirements of PPWR Article 5(4) and the Packaging and Packaging Waste Directive 94/62/EC as amended. Testing of representative samples according to EN 13428:2004 confirms that the combined concentration of lead, cadmium, mercury and hexavalent chromium is below 100 mg/kg. The concentration of environmentally hazardous substances (hazard statements H400, H410 or H411 under Regulation (EC) No 1272/2008) is below 0.1% of product weight.
PFAS (Article 5(5))
Neither Pakkauspojat Oy nor its material suppliers use PFAS as an ingredient or additive in this product category. Sample testing by Combustion Ion Chromatography (CIC) according to EN 15408:2011 shows total fluorine below 50 mg/kg. Where recycled fibers are present, trace amounts of PFAS may occur as carry-over impurities from the recycled fiber stream; this is not the result of deliberate addition. Fully virgin fiber products do not carry this risk. For food-contact use, packaging materials are chosen to prevent any transfer of substances to food in amounts that could affect food safety or quality. In food-contact applications using recycled fibers, an additional functional barrier should be considered if migration prevention is required.
Article 6 – Recyclability
Products in this category are suitable for material recycling and work within the collection, sorting and recycling infrastructure available across the European Union. Until delegated act 6(4) takes effect — anticipated by 1 January 2028 — recyclability is demonstrated through conformity with EN 13430:2004. The party placing the finished package on the market is responsible for conducting its own assessment under EN 13430:2004.
Article 10 – Packaging Minimisation
Packaging weight and volume are kept to the minimum required for the product to perform its intended protective and logistical function. Compliance is demonstrated through conformity with EN 13428:2004 for as long as Article 10 remains transitional, until its full entry into force on 1 January 2030. The party placing the finished package on the market is responsible for conducting its own assessment under EN 13428:2004.
Article 11 – Reusability
Standard corrugated board packaging falls outside the scope of the reuse obligations set out in Article 11. That said, reusable designs are available where customers have a specific requirement for multiple-trip use.
3. Corrugated Board with Plastic Components
This section covers products that include PE or PET liners, and/or wet strength glue. These products are supplied for specific applications requiring moisture resistance or enhanced barrier properties.
Material composition:
Detailed material composition per corrugated board grade is available upon request.
Article 5 – Substance Requirements
Heavy metals (Article 5(4))
On the basis of information from our raw material suppliers, our products meet the requirements of PPWR Article 5(4) and the Packaging and Packaging Waste Directive 94/62/EC as amended. Testing of representative samples according to EN 13428:2004 confirms that the combined concentration of lead, cadmium, mercury and hexavalent chromium is below 100 mg/kg. The concentration of environmentally hazardous substances (hazard statements H400, H410 or H411 under Regulation (EC) No 1272/2008) is below 0.1% of product weight.
PFAS (Article 5(5))
Neither Pakkauspojat Oy nor its material suppliers use PFAS as an ingredient or additive in this product category. Sample testing by Combustion Ion Chromatography (CIC) according to EN 15408:2011 shows total fluorine below 50 mg/kg. Where recycled fibers are present, trace amounts of PFAS may occur as carry-over impurities from the recycled fiber stream; this is not the result of deliberate addition. Fully virgin fiber products do not carry this risk. For food-contact use, packaging materials are chosen to prevent any transfer of substances to food in amounts that could affect food safety or quality. In food-contact applications using recycled fibers, an additional functional barrier should be considered if migration prevention is required.
Article 6 – Recyclability
Products in this category are suitable for material recycling and work within the collection, sorting and recycling infrastructure available across the European Union. Until delegated act 6(4) takes effect — anticipated by 1 January 2028 — recyclability is demonstrated through conformity with EN 13430:2004. The party placing the finished package on the market is responsible for conducting its own assessment under EN 13430:2004.
Article 10 – Packaging Minimisation
Packaging weight and volume are kept to the minimum required for the product to perform its intended protective and logistical function. Compliance is demonstrated through conformity with EN 13428:2004 for as long as Article 10 remains transitional, until its full entry into force on 1 January 2030. The party placing the finished package on the market is responsible for conducting its own assessment under EN 13428:2004.
Article 11 – Reusability
Corrugated board packaging falls outside the scope of the reuse obligations set out in Article 11. That said, reusable designs are available where customers have a specific requirement for multiple-trip use.
4. Standards and Specifications
Total fluorine:
ISO 21646:2022 (sample preparation), EN 15408:2011 (analysis)
Packaging minimisation, Heavy Metals:
EN 13428:2004 – Packaging – Requirements specific to manufacturing and composition – Prevention by source reduction
Recyclability – material recycling:
EN 13430:2004 – Packaging – Requirements for packaging recoverable by material recycling
5. Test Reports
Representative samples have been tested by our material supplier. Detailed test results are considered commercially sensitive information and are made available only to relevant authorities upon request.
Pakkauspojat Oy is a manufacturer of corrugated cardboard packaging. Our products consist of corrugated board made from paper-based raw materials and printing inks commonly used in the packaging industry.
Corrugated cardboard packaging is not classified as hazardous material and is not listed as a marine pollutant under the provisions of the International Maritime Organization (IMO) regulations, including the MARPOL Convention.
As a packaging manufacturer, Pakkauspojat Oy does not issue or hold any MEPC certificates. The Marine Environment Protection Committee (MEPC) is a regulatory body of the IMO rather than a certification scheme.
Based on the nature and composition of our products, corrugated cardboard packaging supplied by Pakkauspojat Oy does not fall within the scope of materials requiring MEPC certification or marine pollutant classification for maritime transport.
DISCLAIMER:
Please note that information above is released according to the information we have received from our material suppliers. This information is based on reasonable investigations and it is accurate to our current knowledge only at the date of this statement release. We take no responsibility for information that has been provided to us by our suppliers. Substances concerning above statements may be found as an impurity in these materials. Also we (or our material suppliers) do not necessarily analyze all the substances listed above since they are not used when materials are manufactured. Nothing in this information is intended to be any kind of warranty and shall not be interpreted as such. It is the responsibility of the user of packages to ensure that packaging materials meet all regulatory and legislative requirements and limitations and is suitable for the purpose that it has been manufactured.
29.05.2026 Klaukkala, Finland
Additional info about our Code of Conduct, company ethics and environmental issues:
Rami Viljamaa
communications
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