A supplier sends you an EN 13432 certificate.
The bag is described as compostable.
Can you now call it a PPWR compliant compostable bag?
Not so fast.
A compostable certificate is useful evidence, but PPWR compliance depends on more than the material.
You also need to know:
- Is the product actually packaging under PPWR?
- Which PPWR rules apply to this packaging?
- Does Article 9 require or allow compostability for this use?
- Does the certificate cover the finished bag?
- What happens to the packaging after use?
- What technical documents are available?
- Which EU Member State will the product enter?
So the answer to the question “Are compostable bags PPWR compliant?” is:
They can meet applicable PPWR requirements, but compostability alone does not make every bag PPWR compliant.
The finished product, application, market and supporting documents all matter.
If you need the wider regulatory background first, read our PPWR compostable packaging guide.
Short Answer: Does Compostable Mean PPWR Compliant?
No.
“Compostable” describes an end-of-life property.
“PPWR compliant” refers to compliance with the applicable requirements of Regulation (EU) 2025/40.
Those are different things.
A bag can have valid industrial-compostability evidence and still need further review under PPWR.
For example, you may still need to check:
- product classification;
- Article 9;
- recyclability pathway;
- packaging minimisation;
- labelling;
- technical documentation;
- traceability;
- conformity assessment.
PPWR applies to packaging placed on the EU market, including imported packaging. It entered into force on 11 February 2025 and generally applies from 12 August 2026.
Source: European Commission — Packaging Waste / PPWR Overview.
This is why I would avoid treating the phrase “PPWR compliant compostable bags” as a certification logo.
There is no single certificate called:
“PPWR Compostable Bag Certificate.”
Compliance is built from the requirements that apply to the specific packaging.
Is the Bag Actually Packaging Under PPWR?
Before checking compostability, start one step earlier.
Ask:
Is this bag packaging?
PPWR defines packaging according to its function.
In simple terms, packaging is generally used to contain, protect, handle, deliver or present products.
That means two bags made from the same material may not have the same PPWR status.
Example 1: Produce Bag
A thin bag used in a supermarket to contain fruit or vegetables can perform a packaging function.
PPWR may therefore apply.
Example 2: E-commerce Mailer
A mailer used to contain and deliver an online order is clearly being used as packaging.
PPWR applies.
Example 3: Household Waste Bag
A bin liner sold empty for collecting household waste may need a different classification because its main purpose is waste collection rather than packaging goods.
Example 4: Dog Waste Bag
A standalone dog waste bag may also fall outside the normal packaging use case.
This matters.
A compostable product can be perfectly valid without being “PPWR packaging.”
Do not force a PPWR claim onto every compostable bag.
Which PPWR Article 9 Path Applies?
Once you confirm that the item is packaging, Article 9 becomes one of the main questions for compostable materials.
Article 9 creates three broad routes.
| Route | Packaging treatment |
|---|---|
| Article 9(1) | Specific packaging must meet industrial compostability requirements |
| Article 9(2) | Member States may require certain additional packaging to be compostable |
| Article 9(3) | Other biodegradable packaging follows a material-recycling pathway |
This is the part that prevents a simple answer such as:
“Compostable is always better under PPWR.”
It is not that simple.
For a full explanation of the three paths, see our PPWR Article 9 guide.
Which Packaging Must Be Compostable?
Article 9(1) requires specific packaging to be compatible with industrially controlled composting by 12 February 2028.
This includes certain:
- permeable tea bags;
- coffee bags;
- other beverage bags;
- soft single-serve beverage units;
- sticky labels attached to fruit and vegetables.
These are applications where the packaging is closely connected to organic material after use.
A tea bag is a simple example.
The tea and the bag often enter the waste stream together.
Making the packaging compatible with bio-waste treatment can therefore have a clear purpose.
But this requirement does not automatically extend to every compostable bag sold in Europe.
Which Bags Can Be Subject to Member State Compostability Rules?
Article 9(2) gives EU Member States some flexibility.
Under defined conditions, a Member State may require certain additional packaging to be compostable.
This can include:
- very lightweight plastic carrier bags;
- lightweight plastic carrier bags;
- certain non-metal beverage-system units;
- some packaging already covered by national compostability rules.
This part matters to bag buyers.
PPWR defines:
Very lightweight plastic carrier bag: below 15 μm.
Lightweight plastic carrier bag: below 50 μm.
A supermarket produce bag could therefore fall into one of these categories.
A 20 μm or 30 μm shopping bag could also fall within the lightweight carrier-bag definition.
But the exact compostability requirement may depend on the Member State.
So do not send a supplier an RFQ that only says:
Market: EU
Tell them the country.
That can change the answer.
What About Other Compostable or Biodegradable Packaging?
This is where many buyers are surprised.
Article 9(3) says that, by 12 February 2028, packaging outside the Article 9(1) and relevant Article 9(2) cases—including packaging made from biodegradable plastic polymers—must be designed for material recycling in accordance with Article 6.
So biodegradable material does not automatically send packaging into the composting stream.
In many applications, PPWR points the packaging toward recycling instead.
This is particularly important for products such as:
- e-commerce mailers;
- some flexible packaging;
- other biodegradable packaging that does not normally enter a bio-waste stream.
For a procurement team, this means:
Start with the waste pathway, not the material claim.
Does EN 13432 Make a Compostable Bag PPWR Compliant?
No.
EN 13432 is important, but it does a different job.
EN 13432 is used to assess packaging for industrial compostability.
It looks at areas such as:
- biodegradation;
- disintegration;
- relevant substance limits;
- effects on compost quality.
That helps answer:
Can this packaging meet industrial compostability criteria?
PPWR asks a wider question:
What requirements apply when this packaging is placed on the EU market?
The European Commission’s 2026 PPWR Guidance explains that the existing EN 13432 can continue to be used as guidance while new or updated harmonised standards are developed.
However, EN 13432 certification alone should not be presented as automatic proof of full PPWR compliance.
If this distinction is new to you, read our PPWR vs EN 13432 guide.
Raw Material Certificate vs Finished Compostable Bag
This is one of the first things I would check when reviewing a supplier.
Imagine you are ordering:
23 × 33 cm
20 μm
Dark green
Black logo print
15 bags per roll
Your supplier sends an EN 13432 certificate.
Good.
Now ask:
What exactly does that certificate cover?
It may cover:
- resin;
- compound;
- base film;
- finished bag;
- certain thickness ranges;
- certain printing systems.
These are not the same.
A finished compostable bag may contain:
- PBAT;
- PLA;
- starch;
- additives;
- colour masterbatch;
- printing ink;
- adhesive;
- labels;
- closures.
That is why the phrase:
“Our raw material is certified.”
should be the start of the discussion, not the end.
A Practical Certificate Check
Before accepting a compostability certificate, I suggest checking:
| Check | Question to ask |
| Certificate holder | Who owns the certificate? |
| Certificate body | Who issued it? |
| Certificate number | Can it be verified? |
| Validity | Is it still current? |
| Product scope | Resin, film or finished bag? |
| Thickness | Does it cover your thickness? |
| Colour | Is the masterbatch within scope? |
| Printing | Is the printed version covered? |
| Components | Are additives and other parts included? |
| Composting route | Industrial or home composting? |
Do not be afraid to ask these questions.
They are normal B2B sourcing questions.
Does Printing Affect PPWR or Compostability?
Printing can matter.
It becomes part of the finished packaging.
Suppose the base film has compostability evidence, but your project adds:
- two-colour logo printing;
- custom Pantone masterbatch;
- an adhesive label.
You now have a different finished product from the plain base film.
That does not automatically mean the product fails.
It means the scope needs to be checked.
For private-label projects, I recommend reviewing the printing and compostability evidence before mass production artwork is approved.
Changing artwork later is expensive.
Checking earlier is much easier.
Industrial Compostable Is Not the Same as Home Compostable
This point is also easy to miss.
EN 13432 is associated with industrial composting conditions.
Industrial composting uses managed conditions such as controlled temperature, moisture and aeration.
Home composting is different.
A backyard compost pile normally operates under lower and less controlled temperatures.
So:
Industrial compostable ≠ automatically home compostable.
If you want to print:
HOME COMPOSTABLE
on the packaging, make sure the claim has separate support.
Do not create a stronger claim than your evidence supports.
You can review our compostable certification information for the differences between common industrial and home-compostability certification routes.
Are Compostable Produce Bags PPWR Compliant?
They can meet applicable PPWR requirements, but you need to check the exact use.
Article 9(1) specifically makes fruit and vegetable sticky labels subject to compostability requirements.
It does not automatically say:
All produce bags must be compostable.
A produce bag may instead fall under the definitions for very lightweight or lightweight plastic carrier bags.
For example:
10 μm produce bag
→ below 15 μm
→ potentially very lightweight plastic carrier bag.
Then the Member State rules become important.
For an EU produce bag project, I would check:
- bag thickness;
- target country;
- intended use;
- food-contact requirements;
- Article 9 pathway;
- certificate scope;
- printing;
- waste route.
- For common B2B formats, see our compostable produce bags.
Are Compostable Shopping Bags PPWR Compliant?
Again, the answer depends on the product and country.
A 20 μm compostable T-shirt shopping bag is below the PPWR 50 μm threshold for lightweight plastic carrier bags.
Article 9(2) allows Member States to require such bags to be compostable under defined bio-waste collection and treatment conditions.
This means the same bag can face different local requirements across Europe.
Before approving the product, check:
- Member State;
- thickness;
- bag format;
- handle type;
- certification;
- printed compostability claim;
- local disposal instructions.
- You can read our compostable shopping bags guide for common supermarket and retail formats.
Are Compostable Mailers PPWR Compliant?
This requires more caution.
A normal e-commerce mailer is not among the packaging formats specifically required to be compostable under Article 9(1).
And Article 9(3) creates a material-recycling pathway for other biodegradable packaging by 12 February 2028.
So this statement is too broad:
“EN 13432 certified mailer = PPWR compliant mailer.”
Instead, review:
- Article 6 recyclability requirements;
- Article 9 classification;
- target market;
- material;
- packaging design;
- printing;
- end-of-life pathway;
- labelling;
- technical documentation.
A compostability certificate can still describe a material property.
But it does not settle the whole PPWR question.
If you are developing e-commerce packaging, see our compostable mailer bags.
Are Compostable Garbage Bags PPWR Compliant?
First ask whether PPWR applies to the product as packaging.
A garbage bag sold as a standalone waste-collection product may have a different regulatory position from a produce bag or shipping mailer.
That means:
Compostability compliance and PPWR packaging compliance should not be treated as the same question.
A municipal food-waste liner may still need:
- compostability certification;
- local waste-system approval;
- tender specifications;
- specific markings.
But those requirements do not automatically mean Article 9 applies in the same way as it does to packaging.
For organics collection applications, see our compostable green bin bags.
Are Compostable Dog Waste Bags PPWR Compliant?
The same principle applies.
A dog waste bag sold as a standalone collection product may not perform a normal packaging function.
So I would not market a dog waste bag simply as:
“PPWR Article 9 compliant.”
First determine whether PPWR packaging rules apply at all.
Then deal separately with:
- compostability;
- claims;
- target market;
- local waste rules.
This is more accurate than adding PPWR to every biodegradable product description.
What PPWR Documents Should an EU Importer Ask For?
This is where the discussion moves beyond certificates.
PPWR places duties on manufacturers and importers.
Manufacturers must ensure packaging complies with applicable Articles 5–12 requirements, carry out the relevant conformity assessment, and prepare technical documentation. Importers also have duties to check conformity assessment, documentation, labelling and manufacturer information before placing imported packaging on the EU market.
Depending on the product, an EU buyer may need to review:
Compostability evidence
- EN 13432 certificate or test evidence
- Certificate number
- Certificate holder
- Validity
- Certificate scope
- Finished-product coverage
Product information
- Material structure
- Film thickness
- Dimensions
- Colour
- Printing
- Ink
- Masterbatch
- Additives
- Intended use
PPWR-related documents
- Technical documentation
- Applicable conformity assessment
- EU Declaration of Conformity
- Product identification
- Traceability information
- Applicable labelling information
Market-specific documents
- Food-contact documentation, if relevant
- Member State requirements
- Retailer requirements
- Local certification or collection-system requirements
A folder containing 20 certificates is not automatically better than a folder containing five.
The documents need to match the product.
What Is the EU Declaration of Conformity?
PPWR includes a conformity-assessment framework.
When the applicable requirements have been demonstrated, the manufacturer draws up an EU Declaration of Conformity.
This document identifies the packaging and states conformity with the applicable PPWR requirements.
It is not the same thing as:
- an EN 13432 certificate;
- a material data sheet;
- a factory certificate;
- a laboratory test report.
Each document has a different job.
PPWR also requires manufacturers to retain the relevant technical documentation and EU Declaration of Conformity for defined periods; for single-use packaging, the Regulation provides for a five-year retention period.
This is why supplier documentation will become a bigger part of EU packaging sourcing.
Manufacturer vs Importer: Who Is Responsible?
This question matters when buying from China.
The Chinese factory may be the manufacturer.
The EU company placing imported packaging on the Union market may be the importer.
Both can have obligations.
Manufacturer
The manufacturer needs to address matters such as:
- applicable PPWR requirements;
- conformity assessment;
- technical documentation;
- product identification;
- Declaration of Conformity;
- traceability.
Importer
The importer needs to check matters such as:
- whether conformity assessment has been carried out;
- whether technical documentation exists;
- whether required marking and labelling are present;
- whether manufacturer information is correct;
- whether the necessary documents accompany the packaging.
So an EU importer should not simply say:
“The factory told me it complies.”
Verification matters.
Five Questions I Would Ask a Compostable Bag Supplier
If I were reviewing an EU compostable packaging quotation, I would start with these five questions.
1. What exactly is certified?
Raw material?
Film?
Finished bag?
Printed finished bag?
2. Which PPWR pathway applies?
Article 9(1)?
Article 9(2)?
Article 9(3)?
Or does the product fall outside PPWR packaging scope?
3. What market is the product made for?
Germany?
France?
Italy?
Several Member States?
4. What technical documents are available?
Ask before production.
Not after the goods arrive.
5. What claim will appear on the bag?
For example:
- compostable;
- industrially compostable;
- home compostable;
- biodegradable.
The stronger the claim, the stronger the evidence should be.
PPWR Compliance Checklist for Compostable Bags
Before approving a bulk order, you can use this simple checklist.
Step 1 — Define the product
- What is the bag used for?
- Is it packaging?
- Who uses it?
- What happens to it after use?
Step 2 — Define the market
- Which country?
- Which retailer?
- Which waste route?
- Are local rules relevant?
Step 3 — Check PPWR pathway
- Article 9(1)?
- Article 9(2)?
- Article 9(3)?
- Other PPWR requirements?
Step 4 — Check compostability
- EN 13432?
- Industrial composting?
- Home composting?
- Finished-product scope?
Step 5 — Check construction
- Material
- Thickness
- Colour
- Ink
- Printing
- Additives
- Adhesive
- Labels
Step 6 — Check documentation
- Product specification
- Certification
- Test reports
- Technical documentation
- Conformity information
- Declaration of Conformity
- Traceability
Step 7 — Check artwork
- Compostability claim
- Disposal instructions
- Required label
- Country-specific wording
Then approve production.
This order is safer than designing the packaging first and asking compliance questions later.
A Realistic Example: A Private-Label Produce Bag
Suppose you are an EU distributor sourcing:
Compostable produce bags
12 μm
Green
300 bags per roll
One-colour printing
The supplier sends an EN 13432 certificate.
What should you do?
First
Check whether the 12 μm bag falls under the very lightweight carrier-bag definition.
It does, because it is below 15 μm.
Second
Check the Member State.
Article 9(2) allows national compostability requirements under certain conditions.
Third
Check the certificate.
Does it cover:
- the film?
- 12 μm?
- green masterbatch?
- printing?
Fourth
Review:
- product specification;
- artwork;
- environmental claim;
- technical documents.
Now you have a product review.
Not just a certificate review.
That is the difference.
Red Flags When a Supplier Says “PPWR Compliant”
I would ask more questions if you see statements such as:
“All our biodegradable bags are PPWR certified.”
PPWR is not one certification scheme for all biodegradable bags.
“Our raw material has EN 13432, so every finished bag complies.”
Certificate scope should be checked against the finished product.
“PPWR requires all EU packaging to become compostable.”
Incorrect.
Article 9 creates limited compostability pathways, while other biodegradable packaging can be directed toward material recycling.
“Home compostable and industrial compostable mean the same thing.”
They do not.
“The same packaging works in every EU country.”
Not always.
Member State requirements can still matter.
These are not reasons to reject a supplier immediately.
They are reasons to ask better questions.
How ORIZON Supports EU Compostable Bag Projects
ORIZON manufactures compostable bags for B2B customers such as importers, distributors, retailers, private-label brands and packaging companies.
We have more than 16 years of production experience, with a manufacturing facility of about 20,000 m², 16 automatic production lines, and monthly capacity of around 500 tons.
Our main product formats include:
- compostable garbage bags;
- compostable supermarket shopping bags;
- compostable produce bags;
- compostable mailers;
- compostable garment bags;
- dog waste bags;
- custom OEM compostable bags.
For EU projects, we prefer to start with the specification.
Tell us:
- target country;
- bag application;
- size;
- thickness;
- colour;
- printing;
- packaging;
- certification requirement;
- order quantity.
Then we can review which product information and available certification documents are relevant to that project.
We do not recommend using the phrase “PPWR compliant” simply because a raw material has a compostability certificate.The claim should match the finished product and the requirements that actually apply.For custom projects, see our OEM compostable bags.
You can also review our certified compostable bags for common B2B formats.
FAQ
Are compostable bags PPWR compliant?
Some compostable bags can meet the PPWR requirements applicable to their use, but compostability alone does not prove full PPWR compliance.
The packaging type, Article 9 pathway, target market, certification scope, technical documentation and other relevant PPWR requirements must also be checked.
Is there a PPWR certificate for compostable bags?
PPWR does not create one universal “PPWR compostable bag certificate.”
Compliance is demonstrated through the applicable requirements, conformity assessment, technical documentation and other supporting evidence.
Does EN 13432 mean a compostable bag is PPWR compliant?
No.
EN 13432 supports assessment of industrial compostability, but it does not cover the full PPWR framework.
Read our PPWR vs EN 13432 guide for more detail.
Does a raw-material certificate cover a finished compostable bag?
Not automatically.
The certificate scope should be checked against the finished film, thickness, masterbatch, printing, inks and other relevant components.
Are compostable produce bags required under PPWR?
Not automatically.
Fruit and vegetable sticky labels are covered by Article 9(1), while some produce bags may fall within the very lightweight or lightweight carrier-bag rules under Article 9(2).
Are compostable shopping bags PPWR compliant?
They can meet applicable requirements, but national rules may matter because Member States can introduce compostability requirements for certain lightweight carrier bags under defined conditions.
Are compostable mailers PPWR compliant?
A compostability certificate alone is not enough.
E-commerce mailers are not specifically required to be compostable under Article 9(1), and other biodegradable packaging can fall under Article 9(3)’s material-recycling pathway.
Are garbage bags covered by PPWR?
Not every standalone waste-collection bag is necessarily packaging under PPWR.
The product should first be assessed against the PPWR packaging definition and its intended function.
What documents should I request from a Chinese compostable bag supplier?
Depending on the project, ask for compostability evidence, certificate scope, finished-product specifications, material and printing information, traceability, applicable technical documentation and conformity information.
Who is responsible for PPWR compliance when importing packaging from China?
The manufacturer and EU importer can have separate obligations under PPWR.
Importers should verify that required conformity assessment, technical documentation, labelling and manufacturer information are in place before placing the packaging on the EU market.
Conclusion
A compostable bag is not automatically a PPWR compliant compostable bag because it carries an EN 13432 certificate.
That certificate can be important.
But it is one part of a wider review.
For EU buyers, I suggest following this order:
- Identify the product and its use.
- Confirm whether it is packaging under PPWR.
- Determine the Article 9 pathway.
- Check the target Member State.
- Review finished-product certification.
- Check material, thickness, printing and other components.
- Review technical documentation and conformity information.
- Approve environmental claims and artwork.
- Then move into production.
The goal is not to collect as many certificates as possible.
The goal is to make sure the evidence matches the product you are actually placing on the market.
If you are sourcing a private-label compostable bag for Europe, send us your target country, bag type, size, thickness, printing requirements and estimated order quantity.
That gives us a practical starting point for reviewing the product specification and available documentation.
This article provides general information for packaging buyers and does not constitute legal advice. Requirements depend on the product, intended use, target Member State and applicable PPWR measures.
