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.

Compostable packaging is 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:

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.

Why Compostable Packaging Matters Under PPWR

Compostable packaging matters because some packaging is commonly disposed of together with organic waste or product residue. In these cases, compostability can help reduce contamination and improve organic waste collection.

However, compostability can also create problems if used incorrectly. Compostable packaging placed into the wrong waste stream may contaminate plastic, paper, or other recycling streams. Consumers may also confuse “biodegradable,” “compostable,” “recyclable,” and “biobased,” leading to incorrect disposal.

The PPWR therefore creates a more controlled approach. Compostability is required for certain packaging types, may be allowed or required by Member States for some bags, and must be supported by technical documentation and labelling.

The official PPWR text explains that tea and coffee bags and certain single-serve units are treated as packaging because they are disposed of together with product residue and can contaminate compostable and recycling streams.

For businesses, this means compostability decisions must be linked to real waste behavior, collection infrastructure, technical standards, and documentation.

Which Packaging Must Be Compostable Under PPWR?

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

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.

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

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

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.

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

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

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.

EN 13432:2000 is a standard to consider and 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

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.

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

Compostable packaging technical file checklist

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.

Packaging may need an on-pack label indicating if a material is compostable, including whether it is home-compostable. Labels and digital codes must be visible, clear, and permanent.

What compostable packaging labels should clarify

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.

Misleading labels or symbols about sustainability or recyclability are not allowed, and environmental claims should be aligned with relevant criteria, methodologies, and calculation rules.

Claims that need 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

When recyclability may be more appropriate

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.

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. The Commission may also expand the list of packaging types that must be compostable where certain criteria are met.

National factors companies should monitor

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 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

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

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

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

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

ComplyMarket capabilities include 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.

ComplyMarket helps companies move from scattered supplier emails, spreadsheets, and artwork files to a structured, traceable, and audit-ready packaging compliance process.