Compostable packaging and PPWR Article 9: when it makes sense to choose it

Many producers ask whether compostable packaging is the answer to the new Packaging and Packaging Waste Regulation (PPWR, Regulation (EU) 2025/40). The short answer is: only in specific cases. PPWR does not treat compostable packaging as a general solution. Article 9 gives it a limited role, where composting brings a real benefit to waste management.

What PPWR Article 9 says

Article 9 deals with compostable packaging. From 12 February 2028, certain types of packaging must be compostable under industrial conditions. These are:

Permeable tea, coffee or other beverage bags, and soft single-serve units that are disposed of together with the product.
Sticky labels applied directly to fruit and vegetables.

Member States can also require compostability for other formats, if collection and treatment infrastructure exists. Examples are lightweight and very lightweight plastic carrier bags, or non-permeable coffee capsules. This means obligations can differ from one country to another. If you sell the same packaging in several markets, you need to check the national rules for each one.

The basic idea is simple: compostable packaging makes sense when it ends up together with food waste, and when separating it from the content is difficult or impossible. Compostable packaging placed in the wrong waste stream can damage recycling, so the regulation limits it on purpose.

How to prove that packaging is compostable

The reference standard is EN 13432. In practice, two certifications are widely recognised:

TÜV Austria OK Compost INDUSTRIAL, for composting in industrial facilities.
TÜV Austria OK Compost HOME, for home composting. This is the stricter of the two, because the material must break down at lower temperatures and in a less controlled environment.

Be careful with wording. Terms like "biodegradable" or "eco" without certification are not proof, and they create a greenwashing risk. Always ask for the certificate and check that it covers exactly the product you are buying.

Examples of solutions on the market

CompoFlex is a range that is compostable both at home and industrially. It is made from PBAT, PLA, PBS, PHA and TPS, has TÜV Austria OK Compost HOME and INDUSTRIAL certification under EN 13432, a storage life of 9 months and a translucent look. It is suitable for food service, pastry shops, floristry and gift packaging.

AquaFlex covers a different niche. It is water soluble, safe for the marine environment, and breaks down in 35 days in fresh water and 45 days in salt water. It has EN 13432, OECD 201 and Marine Safe certifications. It is a solution for special applications, not a general replacement for standard packaging.

Compostable, recycled or bio-based: choose by use case

The practical recommendation is not to choose compostable packaging as a single solution. Choose according to how the packaging is used and collected:

Compostable, where the packaging ends up together with food residues or bio-waste, and where separate bio-waste collection exists.
Recycled, where a working recycling collection stream exists. Here, certified recycled plastic and mono-material design are the right direction.
Bio-based, where you need properties similar to conventional plastic. Be careful: bio-based does not automatically mean compostable or recyclable, so check both aspects separately.

What changes for EPR

Compostable packaging does not escape extended producer responsibility (EPR). You are still required to register, report the quantities placed on the market and pay the fee for that packaging. Reporting by material must be done correctly: compostable packaging is not declared as ordinary plastic, and a wrong classification can lead to extra costs or reporting errors.

Practical steps for your company

Identify the packaging in your portfolio that falls under Article 9 categories (bags, single-serve units, labels on fruit and vegetables).
Check whether the countries where you sell have additional compostability requirements.
Request EN 13432, OK Compost HOME or INDUSTRIAL certificates, and keep them in your compliance file.
For the rest of your packaging, choose between recycled and bio-based according to the real collection stream.
Check that your EPR reporting classification is correct.

Conclusion

Compostable packaging is a good solution for well defined cases, not an answer for the whole portfolio. If you choose it by use case and with clear certification, you reduce the risk of non-compliance and avoid the costs of wrongly chosen packaging.

How ECONOS can help

ECONOS helps you understand what Article 9 means for your products. We analyse your packaging portfolio, check certifications, identify the requirements in each market and correct your EPR reporting. We also train your team, so you can manage compliance on your own over the long term.