Most recycled paper/cardboard products include a small percentage of virgin pulp or pre-consumer recycled paper to reinforce fibers.

Annex I specify that Regulation doesn’t apply to products entirely made from material that has completed its lifecycle and would otherwise be discarded as waste, as defined in Article 3, paragraph 1, of Directive 2008/98/EC. Then, no Regulation obligations apply to recycled material. Conversely, if the product contains a non-recycled material percentage, it falls under Regulation requirements, necessitating tracing of non-recycled material back to its source through geolocation.