---
title: "PPWR compostable packaging rules: what must be compostable?"
canonical_url: "https://www.sorena.io/artifacts/eu/packaging-waste-regulation/faq/compostable-packaging"
source_url: "https://www.sorena.io/artifacts/eu/packaging-waste-regulation/faq/compostable-packaging"
author: "Sorena AI"
description: "A PPWR FAQ on compostable packaging: mandatory compostable formats, Member State options, recycling default rules, labels, and evidence to retain."
published_at: "2026-05-09"
updated_at: "2026-05-27"
keywords:
  - "PPWR compostable packaging"
  - "Article 9 compostable packaging"
  - "EN 13432"
  - "fruit and vegetable labels"
  - "tea coffee bags"
  - "EU packaging waste regulation"
  - "PPWR"
  - "EU Packaging and Packaging Waste Regulation"
  - "compostable packaging"
  - "Article 9"
  - "packaging waste"
---
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# PPWR compostable packaging rules: what must be compostable?

A PPWR FAQ on compostable packaging: mandatory compostable formats, Member State options, recycling default rules, labels, and evidence to retain.

*FAQ* *PPWR* *EU*

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

PPWR does not treat compostability as a general substitute for recyclability. Article 9 creates a narrow compostability route for specified packaging formats, with Member State options for a limited additional set.

Use this FAQ to classify compostable claims, check whether a format falls under Article 9, and keep technical evidence aligned with labels and waste-stream instructions.

Under PPWR, compostable packaging is a specific regulatory category, not a broad green claim. Teams should first check whether the packaging is in Article 9's mandatory or Member State-option groups; if not, the packaging is generally expected to be designed for material recycling without harming other waste streams.

## What should teams do about compostable packaging under PPWR?

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.

- Classify whether the item is a permeable tea, coffee or beverage bag, a soft after-use single-serve unit, a fruit or vegetable sticky label, or another packaging format.
- For Article 9(1) items, document industrial composting compatibility and check Member State home-composting requirements.
- For all other formats, confirm whether Article 9(2) Member State rules apply; otherwise treat material recycling as the default design route.
- Do not use a general compostable claim to bypass PPWR recyclability, labelling, or technical-information duties.

Sources for this answer:

- [Regulation (EU) 2025/40 on packaging and packaging waste](https://data.europa.eu/eli/reg/2025/40/oj?ref=sorena.io) - Article 9 sets the PPWR compostable packaging rule, including the 12 February 2028 date, the Article 3(1)(f) formats, fruit and vegetable sticky labels, Member State options, and the recycling default for other packaging.
- [BS EN 13432:2000](https://knowledge.bsigroup.com/products/packaging-requirements-for-packaging-recoverable-through-composting-and-biodegradation-test-scheme-and-evaluation-criteria-for-the-final-acceptance-of-packaging?ref=sorena.io) - Standards reference for packaging recoverable through composting and biodegradation; useful when checking compostability test evidence and supplier declarations.

## Which packaging can Member States require to be compostable?

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.

- Check Member State rules for target markets before finalising a compostable format or label.
- Verify that the national rule is tied to bio-waste collection and treatment infrastructure.
- Keep separate evidence for Article 9(1) mandatory items and Article 9(2) Member State-option items.
- Track whether the packaging is metal, non-metal, permeable, non-permeable, a carrier bag, or a pre-existing national compostability case.

Sources for this answer:

- [Regulation (EU) 2025/40 on packaging and packaging waste](https://data.europa.eu/eli/reg/2025/40/oj?ref=sorena.io) - Article 9(2) identifies the Member State-option compostability cases and ties them to bio-waste collection and appropriate treatment infrastructure.

## What does PPWR mean by compostable and home compostable packaging?

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.

- Do not equate industrial compostability with home compostability.
- Check whether the claim, label, and disposal instruction specify industrial conditions, home composting, or both.
- Retain test evidence that matches the exact claim and intended waste route.
- Confirm the packaging does not contaminate bio-waste or non-compostable packaging waste streams.

Sources for this answer:

- [Regulation (EU) 2025/40 on packaging and packaging waste](https://data.europa.eu/eli/reg/2025/40/oj?ref=sorena.io) - Article 3 defines compostable packaging and home compostable packaging, including the distinction between industrially controlled conditions and non-controlled home composting conditions.
- [Regulation (EU) 2025/40 on packaging and packaging waste](https://data.europa.eu/eli/reg/2025/40/oj?ref=sorena.io) - Annex III lists conditions to consider when mandating or introducing compostable packaging formats, including organic waste collection benefits and contamination risks.

## How should compostable packaging be labelled?

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.

- Check whether the Article 12 harmonised label timing applies to the packaging and market.
- Make the label consistent with the packaging's actual industrial or home-compostability evidence.
- Avoid consumer wording that implies compostable packaging can be littered or placed in any garden compost.
- Keep label artwork, translations, and technical evidence under change control.

Sources for this answer:

- [Regulation (EU) 2025/40 on packaging and packaging waste](https://data.europa.eu/eli/reg/2025/40/oj?ref=sorena.io) - Article 12 requires harmonised material-composition labels and adds specific warnings for Article 9 compostable packaging.
- [Packaging & Packaging Waste Regulation](https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste/packaging-packaging-waste-regulation_en?ref=sorena.io) - European Commission overview explaining PPWR's broader aim of clearer packaging labelling and harmonised packaging rules across the EU.

## What evidence should teams retain?

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.

- Article 9 classification memo for the packaging format.
- Compostability standard, test report, or supplier declaration tied to the exact packaging specification.
- Member State assessment for Article 9(2) or home-composting requirements.
- Label proof showing compostable, not-home-compostable, and do-not-discard-in-nature wording where required.
- Change log for material, adhesive, ink, coating, supplier, label, or market changes that could affect the compostability conclusion.

Sources for this answer:

- [Regulation (EU) 2025/40 on packaging and packaging waste](https://data.europa.eu/eli/reg/2025/40/oj?ref=sorena.io) - Article 9(4) requires compliance with compostable packaging requirements to be demonstrated in the technical information concerning the packaging.
- [BS EN 13432:2000](https://knowledge.bsigroup.com/products/packaging-requirements-for-packaging-recoverable-through-composting-and-biodegradation-test-scheme-and-evaluation-criteria-for-the-final-acceptance-of-packaging?ref=sorena.io) - Standard entry describing the composting and biodegradation test scheme often referenced for packaging compostability evidence.

## Primary sources

- [Regulation (EU) 2025/40 on packaging and packaging waste](https://data.europa.eu/eli/reg/2025/40/oj?ref=sorena.io) - Official PPWR text for Article 3 definitions, Article 9 compostable packaging requirements, Article 12 labelling, Annex III compostability conditions, and technical-information duties.
  - Quote: "By way of derogation from Article 6(1), by 12 February 2028, where packaging referred to in Article 3(1), point (1)(f), and sticky labels affixed to fruit and vegetables are placed on the market"
- [BS EN 13432:2000](https://knowledge.bsigroup.com/products/packaging-requirements-for-packaging-recoverable-through-composting-and-biodegradation-test-scheme-and-evaluation-criteria-for-the-final-acceptance-of-packaging?ref=sorena.io) - Standards reference for packaging recoverable through composting and biodegradation, relevant to supplier certificates and compostability test evidence.
  - Quote: "Packaging. Requirements for packaging recoverable through composting and biodegradation. Test scheme and evaluation criteria for the final acceptance of packaging"
- [Packaging & Packaging Waste Regulation](https://environment.ec.europa.eu/topics/waste-and-recycling/packaging-waste/packaging-packaging-waste-regulation_en?ref=sorena.io) - European Commission PPWR overview for broader policy context on recyclability, labelling, harmonised standards, and packaging-waste reduction.
  - Quote: "All Packaging must be recyclable by 2030"

## Topic Guides

- [EU PPWR Conformity Documentation Guide](/artifacts/eu/packaging-waste-regulation/conformity-documentation.md): Build PPWR technical documentation and EU declarations of conformity for packaging, with evidence fields, owner checks, retention rules, and official EU sources.
- [EU PPWR penalties and fines: Article 68 enforcement guide](/artifacts/eu/packaging-waste-regulation/penalties-and-fines.md): Source-grounded guide to PPWR penalties and fines: Article 68 Member State rules, administrative fines for Articles 24 to 29, market-surveillance action, formal non-compliance, and enforcement evidence.
- [PPWR applicability test: packaging scope, roles, and evidence](/artifacts/eu/packaging-waste-regulation/applicability-test.md): Determine whether the EU Packaging and Packaging Waste Regulation applies to a packaging item, market activity, operator role, and evidence workflow.
- [PPWR Article 12 labelling, QR codes, and digital carriers](/artifacts/eu/packaging-waste-regulation/labelling-qr-and-digital-carriers.md): source-linked guide to PPWR Article 12 packaging labels, reusable packaging QR codes, digital carriers, online-sale information, and evidence records.
- [PPWR Article 33 refill targets and take-away container reuse obligations](/artifacts/eu/packaging-waste-regulation/reuse-refill-targets.md): source-linked guide to PPWR reuse and refill targets for transport, grouped, beverage, and take-away packaging under Articles 29 to 33.
- [PPWR Article 5 PFAS and Restricted Substances Guide](/artifacts/eu/packaging-waste-regulation/pfas-and-restricted-substances.md): Grounded guide to PPWR Article 5 substance controls: substances of concern, the 100 mg/kg heavy-metal cap, PFAS limits for food-contact packaging, and technical-documentation evidence.
- [PPWR Article 5 PFAS Evidence Workflow for Food-Contact Packaging](/artifacts/eu/packaging-waste-regulation/pfas-evidence-workflow.md): Build a PPWR Article 5 evidence workflow for food-contact packaging PFAS checks, limit-value evidence, supplier proof, and Annex VII technical documentation.
- [PPWR compliance checklist for packaging teams](/artifacts/eu/packaging-waste-regulation/checklist.md): source-linked PPWR checklist for packaging scope, recyclability, recycled content, PFAS, minimisation, labelling, conformity files, and EPR registration under Regulation (EU) 2025/40.
- [PPWR compliance guide: packaging conformity, EPR and evidence](/artifacts/eu/packaging-waste-regulation/compliance.md): Build a PPWR compliance workflow for packaging placed on the EU market, covering Articles 5-12 controls, conformity assessment, technical files, declarations, labelling, EPR and evidence.
- [PPWR deadlines and compliance calendar](/artifacts/eu/packaging-waste-regulation/deadlines-and-compliance-calendar.md): Calendar-style PPWR deadline guide for application, PFAS, labelling, recyclability, recycled content, reuse, refill, deposit return, reporting, and transition dates.
- [PPWR delegated and implementing act tracker](/artifacts/eu/packaging-waste-regulation/delegated-act-tracking.md): Track PPWR delegated and implementing acts for recyclability, recycled content, reuse, labelling, EPR, reporting, and evidence owners.
- [PPWR e-commerce packaging rules: empty space, labels, and reuse](/artifacts/eu/packaging-waste-regulation/faq/e-commerce-packaging.md): source-linked FAQ for online sellers and fulfilment teams applying PPWR rules to e-commerce packaging, including empty-space, labelling, reuse, and evidence records.
- [PPWR Economic Operator Roles: manufacturers, importers, distributors and producers](/artifacts/eu/packaging-waste-regulation/economic-operator-roles.md): Map PPWR roles for packaging teams: manufacturer conformity files, importer and distributor checks, supplier data, fulfilment handling, traceability, and EPR producer registration.
- [PPWR EPR and Producer Responsibility Guide](/artifacts/eu/packaging-waste-regulation/epr-and-producer-responsibility.md): Map PPWR EPR duties for producers, authorised representatives, producer responsibility organisations, online platforms, registrations, reporting and evidence under Regulation (EU) 2025/40.
- [PPWR FAQ: Scope, Recyclability, Reuse, Labelling, and EPR](/artifacts/eu/packaging-waste-regulation/faq.md): FAQ index for Regulation (EU) 2025/40 on packaging and packaging waste, covering PPWR scope, recyclability, recycled content, minimisation, reuse, labelling, EPR, and evidence.
- [PPWR grouped and transport packaging empty-space FAQ](/artifacts/eu/packaging-waste-regulation/faq/grouped-and-transport-packaging.md): Answer whether grouped, transport, and e-commerce packaging need PPWR empty-space controls, what the 50% ratio covers, and what evidence to keep.
- [PPWR labelling and consumer information requirements](/artifacts/eu/packaging-waste-regulation/labeling-and-consumer-info.md): Article 12 and Article 55 PPWR guidance for packaging labels, QR codes, online sales information, waste receptacle labels, and consumer information records.
- [PPWR labelling checklist for Articles 12 and 13](/artifacts/eu/packaging-waste-regulation/ppwr-labeling-checklist.md): Checklist for PPWR Article 12 packaging labels and Article 13 waste-receptacle labels, including material composition, reuse, DRS, digital carriers, online sales, and transition stock.
- [PPWR labelling dates: when do packaging labels apply?](/artifacts/eu/packaging-waste-regulation/faq/labelling-dates.md): A PPWR FAQ on Article 12 and Article 13 labelling dates for packaging, reusable packaging, recycled-content labels, QR codes, waste receptacles, and implementation acts.
- [PPWR labelling rollout workflow for Article 12 and 13](/artifacts/eu/packaging-waste-regulation/labelling-rollout-workflow.md): source-linked workflow for rolling out PPWR Article 12 packaging labels, QR codes, reusable packaging labels, recycled-content labels, and Article 13 waste-receptacle labels.
- [PPWR micro-enterprise and small business FAQ](/artifacts/eu/packaging-waste-regulation/faq/micro-and-small-business-edge-cases.md): source-linked FAQ on PPWR micro-enterprise and small business edge cases, including manufacturer responsibility, reuse exemptions, packaging restrictions, refill, and evidence records.
- [PPWR packaging classification guide: sales, grouped, transport and e-commerce packaging](/artifacts/eu/packaging-waste-regulation/packaging-classification.md): Classify PPWR packaging by function, material category, format, reuse status and operator role before assessing recyclability, restrictions, EPR and documentation.
- [PPWR Packaging Minimisation Guide: Article 10 Evidence](/artifacts/eu/packaging-waste-regulation/minimization.md): source-linked PPWR packaging minimisation guide covering Article 10, Annex IV evidence, perceived-volume bans, empty-space rules, and technical documentation.
- [PPWR packaging scope workflow: classify packaging, roles, and evidence](/artifacts/eu/packaging-waste-regulation/packaging-scope-workflow.md): A PPWR packaging scope workflow for classifying packaging, assigning economic-operator roles, routing EPR questions, and keeping technical evidence.
- [PPWR PFAS Rules for Food-Contact Packaging](/artifacts/eu/packaging-waste-regulation/pfas-and-food-contact-packaging.md): source-linked guide to PPWR Article 5 PFAS limits for food-contact packaging, including the 12 August 2026 date, thresholds, and evidence records.
- [PPWR PFAS Thresholds for Food-Contact Packaging](/artifacts/eu/packaging-waste-regulation/faq/pfas-thresholds.md): Direct FAQ on the PPWR Article 5 PFAS limits for food-contact packaging, including the 25 ppb, 250 ppb, and 50 ppm thresholds.
- [PPWR Recyclability and Design-for-Recycling Requirements](/artifacts/eu/packaging-waste-regulation/recyclability-and-design-requirements.md): Article 6 PPWR guide to packaging recyclability grades, Annex II packaging categories, design-for-recycling parameters, recycled-at-scale assessment, and evidence files.
- [PPWR Recyclability Assessment Template](/artifacts/eu/packaging-waste-regulation/ppwr-recyclability-assessment-template.md): Use this PPWR recyclability assessment template to record packaging category, DfR parameters, performance grade evidence, recycled-at-scale evidence, and approval owners.
- [PPWR Recyclability Assessment Workflow | Article 6 and Annex II](/artifacts/eu/packaging-waste-regulation/recyclability-assessment-workflow.md): Assess PPWR recyclability by packaging unit: map the Annex II category, screen design-for-recycling parameters, grade the result, and retain Annex VII evidence.
- [PPWR recyclability grades A, B and C explained](/artifacts/eu/packaging-waste-regulation/recyclability-grades.md): Understand PPWR recyclability grades under Article 6 and Annex II, including design-for-recycling thresholds, 2030, 2035 and 2038 timing, and evidence records.
- [PPWR recycled content calculations: Article 7 FAQ](/artifacts/eu/packaging-waste-regulation/faq/recycled-content-calculations.md): A PPWR FAQ on recycled content calculations for plastic packaging: Article 7 scope, manufacturing-plant averages, Commission methodology timing, exceptions, and evidence.
- [PPWR Recycled Content Targets for Plastic Packaging](/artifacts/eu/packaging-waste-regulation/recycled-content-targets.md): Article 7 PPWR targets for recycled content in plastic packaging, including 2030 and 2040 percentages, calculation basis, exclusions, and evidence records.
- [PPWR requirements overview for EU packaging teams](/artifacts/eu/packaging-waste-regulation/requirements.md): A grounded overview of Regulation (EU) 2025/40 requirements for packaging scope, recyclability, recycled content, minimisation, labelling, reuse, EPR, and conformity evidence.
- [PPWR reusable packaging and re-use systems FAQ](/artifacts/eu/packaging-waste-regulation/faq/reusable-systems.md): Answer when packaging can be treated as reusable under PPWR, what re-use systems must include, and what evidence teams should keep.
- [PPWR reuse and refill targets: Article 29 and take-away duties](/artifacts/eu/packaging-waste-regulation/reuse-and-refill-targets.md): source-linked guide to PPWR reuse targets for transport, grouped, beverage, and take-away packaging, including Article 29, 32, 33, reporting, and exemptions.
- [PPWR reuse target applicability workflow: Article 29 and 33](/artifacts/eu/packaging-waste-regulation/reuse-target-applicability-workflow.md): source-linked workflow to decide whether PPWR Article 29 reuse targets, Article 32 refill duties, and Article 33 take-away reusable offers apply.
- [PPWR scope and packaging definitions: Article 2 and Article 3 guide](/artifacts/eu/packaging-waste-regulation/scope-and-packaging-definitions.md): Use PPWR Article 2 and Article 3 to decide whether an item is packaging, classify sales, grouped, transport, e-commerce and service packaging, and record source-linked evidence.
- [PPWR service packaging FAQ: point-of-sale and takeaway rules](/artifacts/eu/packaging-waste-regulation/faq/service-packaging.md): Service packaging under the EU PPWR means items designed to be filled at the point of sale. See scope, takeaway, HORECA refill and reuse, and evidence checks.
- [PPWR vs ESPR: Packaging Rules vs Product Ecodesign](/artifacts/eu/packaging-waste-regulation/ppwr-vs-espr.md): Compare PPWR and ESPR without mixing duties: PPWR controls packaging and packaging waste, while ESPR is a separate sustainable-product ecodesign framework that PPWR complements.
- [PPWR vs REACH: Packaging Waste vs Chemicals Rules](/artifacts/eu/packaging-waste-regulation/ppwr-vs-reach.md): Compare PPWR packaging duties with the narrow REACH boundary confirmed in PPWR sources: substances in packaging, PFAS, recyclability, labelling, EPR, evidence, and dates.
- [PPWR vs RoHS: Packaging vs EEE Compliance](/artifacts/eu/packaging-waste-regulation/ppwr-vs-rohs.md): Compare PPWR packaging duties with a separate RoHS workstream, including scope, owners, evidence, dates, overlap limits, and source-linked PPWR decision points.
- [PPWR vs Single-Use Plastics Directive: Packaging Scope and Overlap](/artifacts/eu/packaging-waste-regulation/ppwr-vs-sup-directive.md): Compare PPWR and the Single-Use Plastics Directive without merging duties: all-packaging PPWR rules, listed single-use plastic product rules, overlap, evidence, and 2030 changes.
- [PPWR vs Waste Framework Directive: Packaging Duties and WFD Links](/artifacts/eu/packaging-waste-regulation/ppwr-vs-waste-framework-directive.md): Compare PPWR with the Waste Framework Directive where the PPWR text expressly relies on WFD concepts: waste hierarchy, definitions, EPR, collection, traceability, and waste plans.
- [Timeline and Deadlines for PPWR: practical implementation guide](/artifacts/eu/packaging-waste-regulation/timeline-and-deadlines.md): Practical PPWR guidance for Timeline and Deadlines, with source-linked decisions, owners, evidence records, and implementation steps.

*Recommended next step*

*Placement: after evidence section*

## Turn compostability claims into PPWR evidence

Use this PPWR FAQ to classify compostable packaging, align labels with Article 9 and Article 12, and keep source-linked technical evidence before launch or market expansion.

- [Open Research Copilot](/solutions/research-copilot.md): Answer PPWR implementation questions with cited source material.
- [Discuss PPWR implementation](/contact.md): Review packaging scope, labels, source evidence, and next implementation steps with Sorena.


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