Compostable Packaging Requirements Under PPWR 2026

Compostable packaging is becoming an important but often misunderstood topic under the EU Packaging and Packaging Waste Regulation, known as the PPWR. Many companies assume that compostable or biodegradable packaging is automatically better than conventional packaging. Under the PPWR, the reality is more specific.

Compostability is not treated as a universal replacement for recyclability. In many cases, packaging should still be designed for material recycling. Compostable packaging is mainly relevant where compostability brings a practical environmental benefit, supports organic waste collection, and does not disrupt other recycling systems.

Regulation (EU) 2025/40 on packaging and packaging waste entered into force on 11 February 2025 and will generally apply from 12 August 2026. The European Commission explains that the PPWR covers all packaging and packaging waste, regardless of material or origin, and sets requirements for packaging manufacturing, composition, reusable or recoverable nature, waste management, and waste prevention.

The attached packaging compliance workshop identifies compostable packaging as a dedicated PPWR compliance area. It covers mandatory compostability for certain packaging types, requirements for lightweight plastic bags, the rule that other packaging materials must prioritize recycling, proof of compliance, possible future additions to the compostable packaging list, and technical standards such as EN 13432:2000.

For manufacturers, importers, packaging suppliers, retailers, food and beverage companies, cosmetics companies, e-commerce sellers, and compliance teams, the main message is clear: compostable packaging must be assessed, documented, labelled, and justified carefully.

What Is Compostable Packaging?

Compostable packaging is packaging designed to break down under composting conditions into natural components such as carbon dioxide, water, and biomass, without leaving harmful residues or disrupting the composting process.

However, “compostable” does not always mean the same thing in practice. Companies need to distinguish between:

Term	Practical Meaning
Industrially compostable	Packaging is designed to break down under controlled industrial composting conditions
Home compostable	Packaging is designed to break down under home composting conditions, which are usually less controlled
Biodegradable	A broader term meaning the material can break down biologically under certain conditions
Biobased	Material made fully or partly from biological feedstock, but not automatically compostable or biodegradable
Recyclable	Packaging can be collected, sorted, and reprocessed into secondary raw materials

This distinction is important because a package can be biobased but not compostable. It can be compostable but not home compostable. It can be biodegradable under specific test conditions but not suitable for normal consumer disposal. It can also be compostable but still not the right choice if it contaminates recycling streams.

Under PPWR, compostable packaging should be treated as a specific compliance route, not a general sustainability label.

Which Packaging Must Be Compostable Under PPWR?

The workshop explains that within 24 months after the regulation takes effect, certain packaging types must be compostable in industrial facilities. These include tea bags, single-serve coffee pods or capsules, sticky labels attached to fruit and vegetables, and very lightweight plastic bags such as those used for produce.

Packaging Types Identified for Mandatory Compostability

Packaging Type	Why It Matters
Tea bags	Often disposed of together with tea leaves and organic waste
Single-serve coffee pods or capsules	May be disposed of with coffee residue
Coffee, tea, or beverage system single-serve units	Relevant where packaging and product residue are discarded together
Sticky labels attached to fruit and vegetables	Labels may enter organic waste streams with peels or spoiled produce
Very lightweight plastic bags	Often used for loose produce and may be connected to hygiene or food waste prevention

The PPWR’s official guidance also confirms that the definition of packaging includes permeable tea, coffee, or other beverage bags, soft after-use system single-serve units, and non-permeable tea, coffee, or beverage system single-serve units intended for machine use and disposed of together with the product.

The practical takeaway is that compostability is focused on packaging formats that are likely to enter organic waste streams together with product residue or food waste.

Compostability Is Not the Default for All Packaging

One of the most important PPWR messages is that compostable packaging should not automatically replace recyclable packaging.

The workshop states that starting 24 months after the regulation takes effect, any other packaging, including biodegradable plastics, must allow material recycling and must not disrupt the recycling of other waste materials. Manufacturers must provide technical documentation to demonstrate that packaging meets compostability or recyclability requirements.

This means companies should not assume that switching to compostable plastic is always compliant or preferred. For most packaging, the first question should be:

Can this packaging be designed for material recycling?

Only after that should the company assess whether compostability is required, justified, or allowed.

When recycling may remain the priority

Packaging Situation	Why Recycling May Be Preferred
Packaging is not normally contaminated with food residue	Material recycling may provide better circularity
Packaging is made from widely recycled material	Composting could remove valuable material from recycling streams
Composting infrastructure is limited	Consumers may not have access to the right disposal route
Packaging could contaminate recycling	Compostable plastics may disrupt conventional recycling
Packaging is used in e-commerce or transport	Compostability may not provide a practical end-of-life benefit
Packaging carries vague sustainability claims	Risk of misleading consumers

The business risk is using compostability as a marketing solution instead of a compliance-based design decision.

Industrial Compostability vs Home Compostability

Companies should clearly distinguish between industrial compostability and home compostability.

Industrial compostability means the packaging is designed to break down in controlled industrial composting facilities. These facilities can manage temperature, humidity, oxygen, microbial activity, and processing time.

Home compostability is more difficult because home composting conditions vary widely. Temperature, moisture, turning frequency, and microbial activity are not standardized in the same way.

The PPWR guidance and related coverage indicate that home compostability may be considered only under specific local conditions and under the supervision of relevant authorities. Existing EN 13432 on industrial composting can be used as guidance until new harmonized standards are adopted.

Practical comparison

Compostability Type	Practical Meaning	Business Risk
Industrial compostable	Designed for controlled composting facilities	Risk if consumers do not have access to industrial composting
Home compostable	Designed for home composting conditions	Higher evidence burden due to variable conditions
Biodegradable	Breaks down under certain conditions	Risk of vague or misleading claims
Compostable in one market	Accepted in a specific national system	May not be accepted in another market

Companies should avoid using “compostable” claims without specifying the conditions and evidence behind the claim.

Lightweight and Very Lightweight Plastic Bags

Plastic carrier bags are a specific PPWR topic. Very lightweight plastic carrier bags are particularly important because they are often used for loose food, hygiene purposes, or to prevent food waste.

The EUR-Lex summary explains that very lightweight bags are banned unless used for hygiene or to prevent food waste, and that Member States may decide whether such very lightweight bags must be compostable in their territories.

The workshop also explains that if a country has proper systems to collect and treat compostable packaging as organic waste, that country can require lightweight plastic bags to be biodegradable and compostable in industrial conditions.

Practical implications for businesses

Business Question	Why It Matters
Are very lightweight plastic bags used?	They may be restricted or allowed only for specific purposes
Are they used for hygiene or loose food?	This can affect whether exceptions apply
Does the Member State require compostability?	National rules may differ
Is industrial composting infrastructure available?	Compostability depends on collection and treatment systems
Is the bag labelled correctly?	Consumers need clear disposal instructions
Is evidence available?	Suppliers must support compostability claims

Retailers, grocery businesses, food producers, and produce suppliers should review plastic bag use by country, not only at EU level.

Packaging Types Where Compostability May Be High-Risk

Compostability can be useful for certain packaging, but it can be risky when used for the wrong products or in the wrong waste system.

Packaging types to review carefully

Packaging Type	Risk
Cosmetic sachets	May not enter organic waste and could create misleading compostability claims
E-commerce mailers	Often not connected to organic waste streams
Flexible films	May be confused with recyclable plastic films
Coated paper packaging	Coating may affect compostability and recyclability
Food-contact packaging	Requires both safety and end-of-life assessment
Multi-material packaging	May not compost or recycle properly
Beverage cups	Infrastructure and residue issues vary by market
Disposable cutlery or service items	May fall under other single-use restrictions
Biobased plastic packaging	Biobased does not automatically mean compostable
Packaging with adhesives or inks	Additives may affect compostability evidence

A compostable packaging decision should be based on a structured assessment, not only supplier marketing claims.

Technical Standards for Compostable Packaging

Technical standards are important because they help prove whether packaging is actually compostable.

The workshop references EN 13432:2000 as a standard to consider and notes that it will be updated.

The PPWR also recognizes the role of harmonized standards. Search results from the official regulation text and related regulatory summaries highlight that compostable packaging aligned with harmonized standards may benefit from a presumption of conformity.

What EN 13432 generally supports

Assessment Area	Why It Matters
Biodegradation	Shows the material can biologically break down under composting conditions
Disintegration	Shows the material physically breaks down during composting
Compost quality	Ensures the resulting compost is not negatively affected
Heavy metals and harmful substances	Helps avoid contamination of compost
Test conditions	Provides controlled criteria for assessment

Companies should monitor updates to relevant harmonized standards and avoid relying on outdated certificates or unsupported supplier statements.

Compostable Packaging and Technical Documentation

Compostable packaging must be supported by technical documentation. This is one of the most important compliance steps.

The workshop states that manufacturers must provide technical documentation, as outlined in Annex VII, to demonstrate that packaging meets compostability or recyclability requirements. It also states that other packaging, including biodegradable plastics, must allow material recycling and not disrupt the recycling of other waste materials.

Compostable packaging technical file checklist

Documentation Item	What It Should Show
Packaging description	Packaging type, material, product use, and market
Compostability reason	Why compostability is required or justified
Packaging category	Tea bag, coffee pod, fruit label, very lightweight bag, or other
Compostability type	Industrial compostable or home compostable
Standard or test method	EN 13432 or other applicable standard/method
Test report or certificate	Evidence that packaging meets compostability requirements
Material composition	Polymers, paper, coatings, inks, adhesives, labels, additives
Substance evidence	Heavy metals, PFAS, and other relevant substance checks
Sorting and disposal instructions	How consumers should dispose of the packaging
Recycling disruption assessment	Evidence that the packaging does not disrupt other waste streams
Supplier declaration	Packaging supplier statement and supporting data
Label evidence	Artwork and claim evidence
Declaration of Conformity	Formal statement linked to technical file
Version control	Updates when material, supplier, design, or claim changes

Technical documentation should be prepared before the packaging is placed on the market and updated when the packaging changes.

Compostable Packaging and Labelling

Labelling is essential for compostable packaging because consumers must understand how to dispose of it correctly.

The workshop explains that packaging may need an on-pack label indicating if a material is compostable, including whether it is home-compostable. It also states that labels and digital codes must be visible, clear, and permanent.

What compostable packaging labels should clarify

Label Information	Why It Matters
Whether packaging is compostable	Helps consumers understand the correct disposal route
Industrial or home compostable status	Prevents confusion between different composting conditions
Organic waste stream instructions	Helps prevent contamination of other streams
Local disposal instructions	Composting infrastructure differs by market
Certification or standard reference where appropriate	Supports trust and evidence
QR code or digital information where used	Can provide more detailed disposal guidance
Clear language and pictograms	Improves consumer understanding

Companies should avoid unclear wording such as “eco,” “green,” “earth-friendly,” or “biodegradable packaging” without specific, evidence-based explanations.

Compostability Claims and Greenwashing Risk

Compostability claims can create greenwashing risk when they are vague, exaggerated, or not supported by evidence.

A claim such as “compostable packaging” should be backed by evidence showing the compostability conditions, test method, standard, and disposal route. A claim such as “biodegradable” is even riskier if it does not explain where, how, and under what conditions the packaging biodegrades.

The workshop also highlights that misleading labels or symbols about sustainability or recyclability are not allowed and that environmental claims should be aligned with relevant criteria, methodologies, and calculation rules.

Claims that need evidence

Claim	Evidence Needed
Compostable	Compostability test report or certification
Industrially compostable	Evidence under industrial composting conditions
Home compostable	Evidence under home composting conditions
Biodegradable	Conditions, timeframe, test method, and end-of-life context
Biobased	Biobased content evidence
Plastic-free	Material composition evidence
Eco-friendly	Specific measurable basis, not vague wording
Sustainable packaging	Clear criteria and evidence

A practical rule: if the claim appears on packaging, websites, catalogues, product pages, or marketing material, the technical file should prove it.

Compostable Packaging vs Recyclable Packaging

Companies often ask whether packaging should be compostable or recyclable. Under PPWR, the answer depends on the packaging format, product use, disposal behavior, and waste infrastructure.

When compostability may be appropriate

Situation	Why Compostability May Help
Packaging is disposed of with organic residue	Supports organic waste collection
Packaging is difficult to separate from food waste	Reduces contamination
Packaging is one of the mandatory compostable formats	Compliance requirement applies
Local systems collect and treat compostable packaging	End-of-life pathway exists
Compostable design improves organic waste purity	Reduces non-compostable contamination

When recyclability may be more appropriate

Situation	Why Recycling May Be Better
Packaging is clean and material-recyclable	Material recovery may provide higher circular value
Packaging is not part of organic waste collection	Composting route may not exist
Packaging is made from valuable recyclable material	Composting may remove material from recycling
Compostable packaging could contaminate recycling streams	Consumer confusion can harm recycling
Local composting infrastructure is weak	Claimed end-of-life route may not be realistic

The workshop’s position is clear: other packaging materials, including biodegradable plastics, must prioritize material recycling and must not disrupt the recycling of other waste materials.

Member State Flexibility and National Rules

PPWR creates EU-level rules, but Member States may still have important roles in compostable packaging implementation.

The workshop states that if a country has proper systems to collect and treat compostable packaging as organic waste, the government can require lightweight plastic bags to be biodegradable and compostable in industrial conditions. It also explains that the Commission may expand the list of packaging types that must be compostable where certain criteria are met.

National factors companies should monitor

National Factor	Why It Matters
Organic waste collection system	Determines whether compostable packaging has a practical route
Industrial composting capacity	Supports real compostability claims
Home composting rules	May vary by Member State
Plastic bag rules	Lightweight and very lightweight bag rules may differ
Local labelling systems	Sorting instructions may need country-specific wording
EPR treatment	Compostable packaging may be reported differently
Compostability certification expectations	Local schemes may recognize specific marks or standards

Companies selling across the EU should not assume one compostable packaging label or claim works identically in every Member State.

Can the EU Add More Mandatory Compostable Packaging Types?

Yes, the list of packaging types requiring compostability may change in the future.

The workshop states that the European Commission can expand the list of packaging types that must be compostable, but only if it is technologically feasible and appropriate. For a packaging type to require compostability, it must meet criteria such as being unable to be reusable, being necessary for the product, being designed to enter the organic waste stream, being biodegradable under industrial composting conditions, improving organic waste collection, reducing contamination of compost, and not increasing contamination in non-compostable waste streams.

Criteria for possible future additions

Criterion	Practical Meaning
Cannot be reusable	Reuse is not a practical option
Product cannot exist without packaging	Packaging is necessary
Designed for organic waste stream	Expected disposal route is organic waste
Biodegradable under industrial composting	Must break down under controlled composting conditions
Improves organic waste collection	Helps collect more or better organic waste
Reduces contamination of compost	Prevents non-compostable materials entering compost
Does not contaminate other waste streams	Does not create problems in recycling or residual waste

This is important for packaging innovation. Companies should monitor future EU developments before investing heavily in new compostable packaging formats.

Compostable Packaging and EPR Data

Compostable packaging can also affect Extended Producer Responsibility data and packaging reporting.

Compostable packaging still needs to be identified, classified, and reported where required. Companies may need to know material type, weight, market, compostability status, certification, and whether the packaging is placed in an organic waste stream.

Compostable packaging data companies should collect

Data Category	Examples
Packaging type	Tea bag, coffee pod, sticky label, very lightweight bag, service packaging
Material composition	Plastic, paper, coating, adhesive, ink, additive
Compostability status	Industrial compostable, home compostable, or not compostable
Standard or certification	EN 13432, recognized certification, test report
Product mapping	Which product or SKU uses the packaging
Country placed on market	National rules may differ
Packaging weight	Needed for reporting and EPR
Supplier evidence	Declaration, test report, certification
Label information	Disposal instructions and compostability label
End-of-life route	Organic waste, industrial composting, or other route

Compostable packaging should not sit outside the company’s packaging compliance data system. It should be managed like any other regulated packaging attribute.

Common Mistakes Companies Should Avoid

Compostable packaging requirements can create risk when companies rely on assumptions, incomplete supplier claims, or vague sustainability language.

Common mistakes

Mistake	Why It Creates Risk
Assuming compostable packaging is always preferred	PPWR often prioritizes material recycling
Confusing biobased with compostable	Biobased material is not automatically compostable
Confusing biodegradable with compostable	Biodegradation depends on specific conditions
Using home compostable claims without evidence	Home composting conditions are variable
Ignoring national infrastructure	Compostable packaging needs proper collection and treatment
Using compostable plastic in recycling streams	Can contaminate conventional recycling
Not documenting standards or test results	Claims may not be defensible
Not controlling labels and QR content	Consumers may receive unclear disposal instructions
Applying exemptions without evidence	Authorities may challenge unsupported assumptions
Treating supplier marketing as compliance proof	Supplier claims must be verified and stored

A strong compliance process should replace assumptions with evidence, market mapping, supplier documentation, and controlled labelling.

Practical Compostable Packaging Readiness Roadmap

Companies can use the following roadmap to prepare for compostable packaging requirements under PPWR.

Step 1: Identify compostable or biodegradable packaging in your portfolio

List all packaging marketed as compostable, biodegradable, biobased, organic-waste compatible, or suitable for composting.

Step 2: Classify packaging by format

Identify whether each item is a tea bag, coffee pod or capsule, beverage single-serve unit, sticky label for fruit and vegetables, very lightweight plastic bag, lightweight plastic bag, or another packaging type.

Step 3: Determine whether compostability is required

Check whether the packaging falls under mandatory compostability requirements or whether compostability is optional, national, or claim-based.

Step 4: Assess whether recycling remains the priority

For other packaging types, verify whether the packaging should prioritize material recycling and whether compostability could disrupt recycling streams.

Step 5: Review Member State rules

Check whether national rules require compostability for lightweight or very lightweight plastic bags, and whether organic waste collection infrastructure exists.

Step 6: Collect supplier evidence

Request material composition, compostability certificates, test reports, standard references, substance declarations, and change notification commitments.

Step 7: Prepare technical documentation

Create a technical file showing compostability status, standards used, test evidence, packaging category, disposal route, and labelling evidence.

Step 8: Review labels and claims

Confirm that all compostability, biodegradability, biobased, and environmental claims are accurate, specific, and supported.

Step 9: Connect compostable packaging to EPR data

Record packaging weight, material type, market, supplier, certification status, and end-of-life route for reporting and compliance.

Step 10: Monitor PPWR updates

Track harmonized standards, implementing acts, Commission guidance, and future additions to the mandatory compostable packaging list.

Compostable Packaging Compliance Checklist

Question	Status
Have all compostable or biodegradable packaging items been identified?	To be checked
Is each packaging item mapped to products and countries?	To be checked
Is the packaging one of the mandatory compostable formats?	To be checked
Is it industrially compostable or home compostable?	To be checked
Is there a valid test report or certification?	To be checked
Is EN 13432 or another relevant method referenced?	To be checked
Does the packaging contain coatings, inks, adhesives, or additives?	To be checked
Could the packaging disrupt recycling streams?	To be checked
Is the consumer disposal instruction clear?	To be checked
Are labels and claims supported by evidence?	To be checked
Are Member State-specific rules checked?	To be checked
Is the packaging included in EPR data and reporting?	To be checked
Is the technical documentation complete?	To be checked
Is there version control for supplier or material changes?	To be checked

This checklist can support supplier onboarding, packaging redesign, artwork approval, market launch reviews, and internal audits.

How ComplyMarket Supports Compostable Packaging Compliance

Compostable packaging compliance under PPWR requires more than choosing a compostable material. Companies need to manage packaging classification, supplier evidence, compostability standards, technical documentation, labelling, EPR data, country-specific rules, and claims control.

ComplyMarket’s packaging compliance services explain that packaging compliance can include primary, secondary, and tertiary packaging, as well as plastic, metal, paper, cardboard, glass, wood, labels, inks, coatings, adhesives, and other packaging components. The service page also highlights that packaging compliance may include labelling, material composition, substance restrictions, recycling obligations, registration, reporting, documentation, recordkeeping, recyclability, eco-design, and EPR compliance.

ComplyMarket can help companies prepare for compostable packaging requirements by supporting:

Identification of applicable compostable packaging requirements
Packaging material and component data management
Supplier declaration and certificate collection
Compostability evidence tracking
Technical documentation and Declaration of Conformity support
Labelling and artwork evidence control
Compostability, biodegradability, and biobased claim management
Country-specific packaging requirement tracking
EPR registration and packaging reporting data preparation
Version control for supplier, material, artwork, or claim changes
Audit-ready records for internal and external compliance reviews
Digital Product Passport and circular economy data readiness

The attached workshop identifies ComplyMarket capabilities across product compliance management software, sustainability reporting software, material compliance software, packaging compliance, Extended Producer Responsibility services, Digital Product Passport, and global market access.

For companies managing multiple packaging suppliers, products, and EU markets, the challenge is not only knowing whether packaging is compostable. The real challenge is proving it, labelling it correctly, reporting it accurately, and keeping the evidence updated when materials, suppliers, claims, or rules change.