Compostable packaging vs recyclable: what EU law actually requires

Compostable packaging, biodegradable packaging and recyclable packaging are three different things, and treating them as interchangeable is the most expensive mistake in this area. Recyclable means the pack can be collected, sorted and turned into new material in a stream that exists today. Compostable means it breaks down under controlled composting conditions into compost, not into new material. Biodegradable, used on its own, means almost nothing: it does not say how long, in what environment, or with what left behind.

Two separate pieces of EU law now govern this. Regulation (EU) 2025/40, the PPWR, decides which packaging must be compostable and which must be recyclable. Directive (EU) 2024/825 decides what you are allowed to print on the pack. This page covers both, along with what the certification standards actually prove and what composting plants report in practice.

Compostable packaging, biodegradable and recyclable are not interchangeable

Recyclable describes a pack designed so that it can be collected, sorted and reprocessed into new material. For flexible packaging the practical route is mechanical recycling of single-polymer structures, PE with PE or PP with PP. The design rules are covered on the page about design for recycling.

Compostable describes a material that, under controlled composting conditions, breaks down into carbon dioxide, water and biomass within a defined period, without toxic residues and without degrading compost quality. It does not mean the material disappears anywhere: most compostable packaging needs the conditions of an industrial facility, not a garden heap.

Biodegradable means only that microorganisms can break the material down. With no standard attached, the word carries no timeframe, no environment and no guarantee about residues. Every compostable material is biodegradable; the reverse does not hold, and as of September 2026 the word itself is legally hazardous on a pack.

What EN 13432 proves about compostable packaging

The European reference for industrial compostability of packaging is EN 13432. It requires at least 90% biodegradation within around six months, at least 90% disintegration within around twelve weeks under industrial composting conditions, and no toxic effects on the resulting compost. The equivalents are EN 14995 for non-packaging products, ASTM D6400 and ISO 17088.

Certification is a laboratory result, not a field result

Certification is obtained under controlled conditions and over durations that often exceed the real cycle of a composting plant. The published data diverges sharply, and the decisive variable is not the certificate but the combination of polymer, thickness and plant residence time.

At an Austrian industrial plant, certified bags broke down within the first four weeks (Binner et al., Journal of Material Cycles and Waste Management, 2025). In a six-week industrial trial, thermoplastic starch bags exceeded 95% decomposition while PLA-based bags failed to reach the 90% threshold (Sikander et al., Frontiers in Sustainable Food Systems, 2024). The sharpest contrast comes from a paired lab-and-plant study: a flexible pack that left 0.3% residual mass after twelve weeks in the laboratory still retained 93.9% of its mass after three weeks in the actual plant, simply because the plant cycle was shorter than the certification test (Chong et al., Open Research Europe, 2022). At the other end of the range, a four-month full-scale windrow process achieved 98% mass loss with no adverse effect on compost quality (Gastaldi et al., Bioresource Technology, 2024).

Home compostable packaging is a separate, weaker promise

Home composting requires its own certification, such as OK compost HOME, because a garden heap never reaches industrial temperatures. Even that certification translates poorly into practice: in a UK citizen-science study across 1,648 households, 60% of items certified as home compostable did not fully disintegrate (Purkiss et al., The Big Compost Experiment, 2022). Certification is a necessary condition, not a promise that the pack disappears in every facility and every cycle.

Compostable packaging, recyclable and biodegradable side by side

Indicative comparison. The classification of a specific pack depends on its full structure and on the collection and treatment infrastructure available in the market where it is sold.

Why compostable packaging contaminates the recycling stream

Compostable packaging and conventional plastics are not easily separated at automated sorting, because sorting lines were not built to distinguish them. A share of compostable packaging therefore ends up in the plastic stream, where it behaves as a contaminant and lowers the quality of the recyclate. The reverse failure is just as real: a conventional plastic that reaches a composting facility stays there as a fragment.

The practical conclusion is to pick one clear route per pack and design for it. For industrial flexible packaging, the route that scales and that the legislation actually backs is recycling, through mono-material structures designed for recycling. Compostable makes sense where the product reaches organic waste together with its packaging, not as a universal substitute for recyclable plastic.

When PPWR requires compostable packaging: Article 9 in three tiers

Recyclability is the general requirement: from 1 January 2030, packaging must reach a design-for-recycling grade to be placed on the EU market, as set out on the page about PPWR recyclability grades. Compostability is the exception, and Article 9 splits it into three tiers that are routinely confused with each other.

Mandatory across the EU

Article 9(1) requires industrial compostability by 12 February 2028 for two categories only: the packaging defined in Article 3(1)(1)(f), meaning permeable tea, coffee or other beverage bags and soft single-serve units that contain the beverage and are disposed of with it, plus sticky labels affixed to fruit and vegetables. That is the entire mandatory list.

A national option, not an EU obligation

Article 9(2) lets a Member State that collects bio-waste separately and has the treatment infrastructure require compostability on its own territory for non-permeable single-serve units intended for a machine, other than metal ones, defined in Article 3(1)(1)(g), and for lightweight and very lightweight plastic carrier bags. Rigid coffee capsules sit here. Absent a national decision, they carry no compostability obligation.

Everything else, including biodegradable plastics

Article 9(3) closes the question for the rest of the market. By 12 February 2028, any packaging outside the first two tiers, including packaging made of biodegradable plastic polymers and other biodegradable materials, must be designed for material recycling in accordance with Article 6, without affecting the recyclability of other waste streams.

What you may print on the pack from 27 September 2026

A second and separate instrument governs the wording. Directive (EU) 2024/825 amends the Unfair Commercial Practices Directive, and Member States apply the national measures from 27 September 2026. It adds three entries to the blacklist of practices that are unfair in all circumstances.

Point 4a prohibits making a generic environmental claim for which the trader cannot demonstrate recognised excellent environmental performance relevant to the claim. Recital 9 of the Directive names the examples, and biodegradable is on that list, alongside eco-friendly, green, ecological, climate friendly and biobased. The Directive goes further and observes that a claim such as biodegradable cannot be justified through the EU Ecolabel, because the Ecolabel criteria contain no biodegradability requirements for the products concerned.

Point 4b prohibits making an environmental claim about the entire product when it concerns only one aspect of it. For packaging this is the familiar trap of printing recyclable on a pack where only the film qualifies and the closure or label does not.

Neither the PPWR nor this Directive applies in Great Britain. A pack sold there falls under the CMA Green Claims Code instead, which reaches similar conclusions by a different route.

The decision test: compostable packaging or recyclable

The starting question is not which word sounds greener, but which waste stream the pack realistically reaches.

Where the answer is recyclable, the practical work is structural: moving the pack to a single-polymer design that a sorting line can read and a recycler can process. That programme is set out on the page about the transition to mono-material packaging, and the barrier trade-off it forces on the page comparing metallised film and EVOH.

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