PPWR compostable packaging rules What must be compostable, and what still has to be recyclable?

Start by separating mandatory compostability from voluntary compostable marketing. By 12 February 2028, PPWR Article 9 requires the Article 3(1), point (1)(f) packaging category and sticky labels affixed to fruit and vegetables, when placed on the market, to be compatible with industrial composting standards in bio-waste treatment facilities.

Article 3(1), point (1)(f) covers permeable tea, coffee or other beverage bags and soft after-use system single-serve units that contain those products and are intended to be used and disposed of together with the product. For those formats, keep the compostability evidence with the packaging technical information and verify whether a target Member State also requires home-composting compatibility.

For packaging outside Article 9(1) and Article 9(2), do not assume a compostable claim is enough. Article 9 says other packaging, including packaging made from biodegradable plastic polymers or other biodegradable materials, must be designed for material recycling by 12 February 2028 without affecting the recyclability of other waste streams.

PPWR gives Member States a conditional option, not a blanket power over every package. Where a Member State allows waste with similar biodegradability and compostability properties to be collected together with bio-waste, and has suitable collection and treatment infrastructure, it may require certain additional packaging to be made available on its territory only if compostable.

That optional group includes non-metal Article 3(1), point (1)(g) packaging, very lightweight plastic carrier bags, lightweight plastic carrier bags, and packaging that the Member State already required to be compostable before PPWR's date of application. Article 3(1), point (1)(g) covers non-permeable tea, coffee or other beverage system single-serve units intended for use in a machine and used and disposed of together with the product.

PPWR defines compostable packaging by reference to biological decomposition in industrially controlled conditions, including anaerobic digestion, and by the requirement that the packaging must not hinder or jeopardise separate collection, composting, or anaerobic digestion.

Home compostable packaging is narrower for claims and evidence because it concerns biodegradation outside industrial-scale composting facilities, performed by private individuals for their own compost. Article 9(1) packaging must meet home-composting standards only where Member States require that compatibility.

Article 12 adds a specific consumer-facing point for compostable packaging. For packaging covered by Article 9(1) and, where applicable, Article 9(2), the harmonised label must say that the material is compostable, that it is not suitable for home composting, and that compostable packaging must not be discarded in nature.

That means label approval should not stop at a compostable logo or supplier certificate. Teams should align the label, disposal instruction, material-composition label, technical file, and Member State market assessment before placing the packaging on the market.

Keep evidence that proves the packaging was classified correctly and that the claim matches the waste route. For PPWR compostable packaging, the most important record is the Article 9 classification: mandatory Article 9(1), Member State-option Article 9(2), or outside those categories and therefore routed through material-recycling design.

The technical file should also show the applicable composting standard or test route, Member State home-composting assessment where relevant, labelling review, supplier declarations, and any review of bio-waste infrastructure or contamination risk used for the decision.