What customers repeatedly want to know – questions and answers

We have put together for you the answers to the most frequently asked questions about a wide range of different topics relating to paper production and safe use with foodstuffs. If your concern or question has not been addressed, we ask you to get in touch with us.

What raw materials are used in paper production?
  • Unsorted mixed recovered paper (may contain newspapers)
  • Sorted mixed recovered paper (may contain newspapers)
  • Supermarket recovered paper
  • New shavings of corrugated board
  • Used corrugated kraft 1
  • Used corrugated kraft 2
  • Unused kraft sacks
  • Unused kraft paper Unused, uncoated liquid packaging board without aluminium or PE (production waste)
  • Long fibre sulphate pulp

Beyond that, the following recovered paper types are not used for the production of containerboard at Propapier:

  • Newspapers
  • Unsold newspapers
What additives are used in the papers?

REACH Regulation (EC) No. 1907/2006

Pursuant to the REACH Regulation, the qualities produced by Progroup Paper are “products” which are not subject to the registration requirement.
As a so-called “downstream user”, our plants are not subject to the REACH registration requirement either. However, we can assure you that, at present and in the future, we will only use raw materials, additives and finishing substances which are registered pursuant to the REACH Regulation.

Biocides & preserving agents

The biocides & preserving agents used in our production are in compliance with the current Regulation (EU) 528/2012 and are used to treat the water loop. There is no direct application in the final product. The use of Methylisothiazolinone can occur, but there are no residues detectable in the products (detection limit 0.5 𝛍g/dm2).

Radioactive contamination

We assure you that no radioactive contamination takes place in our plant.

Mineral oils

No additives containing mineral oils (MOSH / MOAH) are used in the production process of Progroup Paper. Due to the use of recycled papers, the inclusion of such oils cannot be excluded as mineral oils may be part of the printing inks used.
The quantitative analysis of the mineral oil content is conducted as part of the regular “testing of paper grades for food safety” and is shown in the latest test report.

Nanoparticles / nanotechnology

No nanoparticles or nanotechnology are used.

Genetically modified organisms (GMOs)

No GMOs are used.

Other ingredients

For the production of our papers, no additives are used which contain PVC, PVdC, PC, PS, bisphenol A, butylhydroxyanisol, Parabens, CFC, HHC, PFCA, PFSA, PFASS, FTOH, monoPAPs, diPAPs, S-diPAPs, SCCP, asbestos, anthraquinone, phthalates, latex or dimethylfumarate. Due to the use of the raw materials, the inclusion cannot be excluded, but is to be classified overall as very small. In addition, the additive Bioban P 1485 and animal fats are not used in our process.
During the production process silicone-containing additives may be used, but are not included or do not merge into the final product.


To prevent the trade in illegal timber and timber products, for imports or exports of cellulose products beyond the borders of the EU, we strictly adhere to the trade and customs laws, as amended from time to time, for instance:

  • European Timber Regulation, Regulation (EU) No 995/2010 of the European Parliament and of the Council
  • EU Forest Law Enforcement, Governance and Trade action plan
  • Lacey Act for imports / exports from/to the USA
What certificates does Progroup Paper have?

FSC® certification (FSC-C106840) according to standard FSC-STD-40-004 version 2-1 and FSC-STD-40-007 version 2-0.

UMS pursuant to Regulation (EC) No. 1221/2009 (EMAS III Regulation)
FSC® certification (FSC-C106924) according to standard FSC-STD-40-004 version 2-1 and FSC-STD-40-007 version 2-0.

Is there an independent clearance declaration for the papers?

The grades produced by Progroup Paper – Promedium, Proliner, Promedium S, Promedium K, Proliner K and Prokraft – are safe to be used as food packaging. They may be in direct contact with dry, non-greasy food. Dry, non-greasy foods with a large surface area (e.g.: rice, pasta, semolina) may be packaged with the additional use of suitable intermediate packaging.

The food safety of the paper grades is regularly checked and updated.

The declaration of no objection is in compliance with:

  • Regulation (EC) No. 1935/2004 of the European Parliament and Council, as of 18.07.2009
  • Directive RoHS 2011/65/EU, as of 08.06.2011
  • German Food, Consumer Goods and Feeding Stuff Code (Lebensmittel-, Bedarfsgegenstände- und Futtermittelgesetzbuch - LFGB), as of 01.12.2104
  • German Recommendation XXXVI, as of 01.07.2015
  • Directive 94/62/EC on packaging and packaging waste, as of 07.02.2013
  • Model Toxics Legislation, last amended in December 2008
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