If you buy compostable packaging for Europe, PPWR Article 9 is one of the sections you need to understand.
But it is also easy to misunderstand.
Article 9 does not say that all biodegradable or compostable packaging should be compostable.
It actually creates three different paths:
- Some packaging must meet compostability requirements.
- Some packaging may be required to be compostable by individual EU Member States.
- Most other biodegradable packaging must follow a material-recycling pathway.
That third point is often missed.
For an EU importer, distributor or private-label brand, the first question should therefore not be:
“Can this package be made compostable?”
A better question is:
“Which PPWR Article 9 pathway applies to this packaging?”
In this guide, I will explain those three paths in practical terms and show what they can mean for produce bags, shopping bags, mailers and other compostable packaging.
For a broader overview of the regulation, see our PPWR compostable packaging guide.
PPWR Article 9 at a Glance
Here is the simplest way to understand the rule.
| PPWR pathway | Packaging | What happens |
|---|---|---|
| Article 9(1) | Certain permeable tea, coffee and beverage bags, certain soft single-serve units, and fruit/vegetable sticky labels | Must meet industrial compostability requirements by 12 February 2028 |
| Article 9(2) | Certain non-metal beverage-system units, very lightweight and lightweight plastic carrier bags, plus some existing national categories | Member States may require them to be compostable under defined conditions |
| Article 9(3) | Other packaging, including packaging made from biodegradable plastic polymers | Must be designed for material recycling by 12 February 2028 |
That is the basic structure of PPWR Article 9.
The main lesson is simple:
Compostable does not automatically mean Article 9 requires composting.
The packaging type comes first.
What Is PPWR Article 9?
Article 9 of Regulation (EU) 2025/40 is titled “Compostable packaging.”
It sits inside the wider Packaging and Packaging Waste Regulation, or PPWR.
PPWR entered into force in February 2025 and generally applies from 12 August 2026. It covers packaging placed on the EU market, including imported packaging.
Article 9 deals specifically with the end-of-life route for compostable and biodegradable packaging.
But it does not create one rule for all compostable products.
Instead, it separates applications according to how the packaging is used and how it is likely to enter the waste stream.
This matters for B2B buyers.
A compostable coffee bag, a supermarket produce bag and an e-commerce mailer may all contain biodegradable polymers.
That does not mean PPWR treats them in the same way.
Path 1: Which Packaging Must Be Compostable Under Article 9(1)?
Article 9(1) contains the clearest EU-wide compostability requirement.
By 12 February 2028, certain packaging placed on the EU market must be compatible with industrially controlled composting in bio-waste treatment facilities. citeturn978638view1
The main categories are:
- certain permeable tea bags;
- certain permeable coffee bags;
- other permeable beverage bags;
- certain soft after-use single-serve beverage units;
- sticky labels attached to fruit and vegetables.
These categories come partly from the PPWR definition of packaging in Article 3(1)(1)(f). That definition covers permeable tea, coffee or other beverage bags and soft after-use single-serve units that contain a beverage and are intended to be used and discarded together with the product.
A simple example
Think about a tea bag.
The tea leaves and the bag normally stay together after use.
If the consumer puts the tea waste into a bio-waste stream, a non-compostable tea bag can introduce unwanted material into that stream.
This is the kind of use case Article 9(1) targets.
The European Commission’s 2026 guidance also explains that this provision is material-neutral. A qualifying tea or coffee unit may therefore fall within the rule even if it is paper-based rather than plastic-based.
That is an important detail.
PPWR Article 9 is about the packaging format and waste pathway, not simply whether the packaging is made from a “bioplastic.”
Are Fruit and Vegetable Bags Required to Be Compostable?
This is where buyers need to read Article 9 carefully.
Article 9(1) specifically mentions:
sticky labels attached to fruit and vegetables.
It does not say that every fruit and vegetable bag must automatically be compostable.
That distinction matters for produce packaging.
A sticky apple label and a roll of supermarket produce bags are not the same packaging format.
For a produce bag, you may also need to examine whether it is classed as a very lightweight plastic carrier bag or a lightweight plastic carrier bag.
PPWR defines:
- very lightweight plastic carrier bags: wall thickness below 15 microns;
- lightweight plastic carrier bags: wall thickness below 50 microns.
These categories are relevant to Article 9(2), not the automatic Article 9(1) requirement.
So if you are sourcing a 10 μm or 12 μm compostable produce bag for a supermarket chain, do not simply say:
“PPWR requires all produce bags to be compostable.”
That is too broad.
Check the bag format, thickness, intended use and target Member State first.
For common wholesale formats, see our compostable produce bags.
Path 2: Which Packaging May Be Required to Be Compostable by Member States?
Article 9(2) creates a different path.
It gives EU Member States some room to require additional packaging to be compostable—but only under defined conditions.
These conditions include suitable bio-waste collection schemes and treatment infrastructure that can ensure the compostable packaging enters the bio-waste stream.
This is not a blanket permission.
The local waste system matters.
Article 9(2) can cover:
- certain non-metal, non-permeable tea, coffee or beverage system single-serve units;
- very lightweight plastic carrier bags;
- lightweight plastic carrier bags;
- certain other packaging already subject to national compostability requirements before PPWR became generally applicable.
The beverage units referred to here are different from the permeable bags under Article 9(1).
Article 3 defines them as non-permeable tea, coffee or other beverage system single-serve units intended for use in a machine and disposed of together with the product.
Coffee capsules are an easy example.
Whether a particular non-metal capsule must be compostable can depend on the Member State and its bio-waste system.
Why Member State Rules Matter for Compostable Shopping Bags
This part is particularly relevant to buyers of compostable shopping bags.
Article 9(2) allows Member States to require very lightweight and lightweight plastic carrier bags to be compostable when the required collection and treatment conditions are in place.
So a supermarket project in one EU country may not have exactly the same requirements as a project in another.
That affects decisions such as:
- bag thickness;
- material;
- compostability claim;
- certification;
- disposal instructions;
- printing;
- local wording.
There is also a separate PPWR rule under Article 34 aimed at reducing consumption of lightweight plastic carrier bags. Member States must maintain measures to keep annual consumption within the PPWR target.
This means “compostable” does not remove every other carrier-bag rule.
If you are planning a retail bag project, see our compostable shopping bags guide.
Then check the specific rules in the country where the bags will be placed on the market.
Can a Member State Require More Packaging to Be Compostable?
Yes, within the limits set by PPWR.
The Commission’s 2026 guidance explains that Member States could maintain certain additional compostability requirements that existed before the PPWR application date. The guidance also stresses that national rules should be communicated clearly so businesses know which packaging formats are affected.
This creates an important sourcing lesson.
“EU compliant” can be too general for some compostable packaging projects.
Your supplier should know the target country.
Instead of writing this in your RFQ:
Market: Europe
write:
Market: Germany
or:
Market: France and Belgium
That gives both buyer and supplier a better starting point for checking local requirements.
Path 3: What Happens to Other Biodegradable Packaging?
This is probably the most important sentence in Article 9 for many packaging buyers.
Article 9(3) states that, by 12 February 2028, packaging outside the Article 9(1) and Article 9(2) categories—including packaging made from biodegradable plastic polymers and other biodegradable materials—must be designed for material recycling under Article 6, without harming the recyclability of other waste streams.
This changes how buyers should think about compostability.
PPWR does not say:
Biodegradable packaging = composting route.
Instead, the default route for other biodegradable packaging becomes:
material recycling
unless the packaging falls into one of the specific Article 9 compostability pathways.
This is why the phrase:
“It is compostable, so it must be PPWR compliant.”
does not work.
The first step is classification.
PPWR Article 9: Three Paths Compared
For procurement teams, I would reduce Article 9 to this decision table.
| Question | Path |
| Is it packaging covered by Article 3(1)(1)(f), or a sticky fruit/vegetable label? | Article 9(1): industrial compostability pathway |
| Is it a qualifying non-metal beverage unit or lightweight/very lightweight carrier bag, and has the Member State required compostability under the Article 9(2) conditions? | Article 9(2): Member State compostability pathway |
| Is it other biodegradable packaging? | Article 9(3): material-recycling pathway |
That is a useful starting point.
But it is not the whole compliance review.
Packaging design, labelling, technical documentation and other PPWR requirements can still apply.
What Does Article 9 Mean for Compostable Mailer Bags?
Compostable mailers are a good example of why Article 9 needs careful reading.
A standard e-commerce mailer is not one of the packaging formats specifically listed in Article 9(1).
So an EN 13432 certificate by itself does not place a compostable mailer into the Article 9(1) composting pathway.
For packaging outside Article 9(1) and relevant Article 9(2) cases, Article 9(3) points toward material recycling by 12 February 2028.
That means an EU buyer considering compostable mailers should review more than compostability.
Check:
- target market;
- packaging classification;
- Article 6 recyclability pathway;
- material structure;
- printing;
- labelling;
- environmental claims;
- technical documentation;
- end-of-life route.
You can review our compostable mailer bags for available formats.
But for EU projects, the regulatory pathway should be confirmed before final artwork and mass production.
What About Compostable Food-Waste Bags?
Food-waste bags need a different first question:
Is the product actually “packaging” under PPWR?
Not every bag is packaging.
PPWR defines packaging based on the function the item performs. Annex I also gives examples showing that an item can be packaging in one use case and not packaging in another.
A standalone food-waste liner used to collect household waste may therefore need to be classified before PPWR is applied to it.
This does not mean compostability standards are unimportant.
They can still matter greatly to:
- municipal bio-waste schemes;
- composting facilities;
- waste operators;
- retailers;
- local tender requirements.
But do not call every compostable bin liner a “PPWR Article 9 product” simply because the material is compostable.
Our compostable bags for green bins page covers common food-waste collection applications.
What About Compostable Dog Waste Bags?
The same caution applies to dog waste bags.
A dog waste bag sold as a standalone collection product may not perform a packaging function under PPWR.
So Article 9 should not automatically be used as a marketing claim for the product.
For B2B buyers, this distinction matters.
A product can have valid compostability certification without being packaging covered by PPWR.
Compostability certification and PPWR scope are two different questions.
Does Article 9 Require EN 13432?
EN 13432 remains an important European reference for industrial compostability.
But the relationship between PPWR Article 9 and EN 13432 needs some care.
Article 9(6) requires the Commission to request new or updated harmonised standards setting out detailed technical specifications for compostable packaging.
The European Commission’s 2026 guidance says that the existing EN 13432 standard can be used as guidance until the new standard is adopted.
However, the existing certification does not by itself create the new PPWR presumption of conformity. That presumption will depend on the relevant harmonised standards being formally listed in the Official Journal of the EU.
So the safe B2B answer is:
EN 13432 still matters.
But:
EN 13432 certification alone does not prove full PPWR Article 9 compliance.
For a detailed comparison, read our PPWR vs EN 13432 guide.
Industrial Compostable vs Home Compostable Under Article 9
Another common mistake is to treat these terms as interchangeable.
They are not.
Industrial composting
Industrial composting takes place in controlled treatment facilities.
Temperature, moisture, aeration and processing conditions can be managed.
Article 9(1) requires the relevant packaging to be compatible with standards for composting under industrially controlled conditions.
Home composting
Home composting normally operates at lower and less controlled temperatures.
Article 9(1) says packaging must also meet home-composting standards where Member States require this.
The Commission guidance makes clear that home-composting requirements should be considered in specific local conditions rather than assumed across the whole EU.
So do not print:
HOME COMPOSTABLE
simply because your bag meets an industrial compostability standard.
The claim needs separate support.
Does PPWR Article 9 Affect Labelling?
Yes.
Article 12 contains specific labelling rules for Article 9 compostable packaging.
For packaging covered by Article 9(1), and applicable packaging under Article 9(2), the label must tell users that:
- the material is compostable;
- it is not suitable for home composting;
- it should not be discarded in nature.
The home-composting statement needs to be considered alongside any Member State requirement that specifically allows or requires home compostability.
PPWR is also introducing harmonised packaging labels according to its implementation timeline.
For private-label buyers, the practical lesson is:
Do not finalise your printed disposal claim too early.
Check:
- packaging category;
- target Member State;
- applicable compostability standard;
- certification scope;
- current PPWR labelling requirement.
Then approve the artwork.
Article 9 Compliance Must Be Supported by Technical Information
Article 9 does not stop at material claims.
Article 9(4) says compliance with paragraphs 1, 2 and 3 must be demonstrated in the technical information concerning the packaging under Annex VII.
This is important for EU importers.
A supplier sending you a photo of a compostability logo is not the same as having the technical information needed for the finished packaging.
Depending on the project, review:
- product specification;
- material composition;
- film thickness;
- certification scope;
- test evidence;
- colour masterbatch;
- ink and printing;
- intended use;
- product identification;
- traceability;
- applicable conformity information.
The document set should match the bag you actually buy.
Raw Material Certificate vs Finished Packaging
Here is a practical example.
Suppose you want:
12 μm green compostable produce bags, 300 bags per roll, printed with one colour.
Your supplier sends an EN 13432 document for the raw material.
That document is useful.
But you should still ask:
- Does the certification scope cover the finished film?
- Is 12 μm included?
- Is the green masterbatch covered?
- Is the printing ink covered or separately assessed?
- What is the intended market?
- Does Article 9(2) apply in that Member State?
- What final claim will appear on the bag?
That is a much stronger B2B review.
The material is only one part of the finished product.
PPWR Article 9 Buyer Checklist
Before ordering compostable packaging for Europe, I suggest checking these points:
Packaging classification
- What is the product used for?
- Is it packaging under PPWR?
- Does Article 9(1), 9(2) or 9(3) apply?
Market
- Which EU Member State?
- Are there national compostability rules?
- What local bio-waste infrastructure exists?
Product
- Size
- Thickness
- Material
- Colour
- Printing
- Additives
- Packaging format
Compostability
- Industrial or home composting?
- What standard is used?
- Is the evidence for raw material or finished packaging?
- Is the certificate still valid?
Documentation
- Technical information under Annex VII where applicable
- Product specification
- Certification scope
- Traceability
- Applicable conformity documents
- Artwork and environmental claims
One word—“compostable”—is not enough to complete this review.
PPWR Article 9 for Produce Bags vs Shopping Bags
These two products can look similar.
But their intended use can change the compliance review.
Produce bag example
A thin roll bag supplied in a supermarket produce section may be a very lightweight carrier bag.
If it is below 15 μm, it fits the PPWR definition of a very lightweight plastic carrier bag.
The target Member State then becomes important because Article 9(2) may allow national compostability requirements.
Shopping bag example
A 20 μm or 30 μm T-shirt bag would fall below the 50 μm threshold for a lightweight plastic carrier bag.
Again, Article 9(2) may become relevant where the Member State has the required bio-waste system and adopts a compostability requirement.
So thickness is not just a cost question.
It can also affect product classification.
Three Mistakes I Would Avoid as a Buyer
Mistake 1: “All compostable packaging is encouraged by PPWR”
No.
Article 9(3) clearly creates a material-recycling pathway for other biodegradable packaging.
Mistake 2: “Every produce bag must become compostable”
No.
Article 9(1) specifically names sticky fruit and vegetable labels. Produce bags need their own classification.
Mistake 3: “EN 13432 means PPWR Article 9 compliant”
Not automatically.
The standard supports industrial compostability assessment, but PPWR requires a wider review and updated harmonised standards framework.
These three mistakes can lead to the wrong product, the wrong artwork or the wrong claim.
How ORIZON Supports Compostable Bag Projects for EU Buyers
At ORIZON, we manufacture compostable bags for B2B customers such as importers, distributors, retailers, private-label brands and packaging companies.
We have more than 16 years of manufacturing experience.
Our facility covers about 20,000 m², with 16 automatic production lines and monthly production capacity of around 500 tons.
Our bag formats include:
- compostable garbage bags;
- compostable supermarket shopping bags;
- compostable produce bags;
- compostable mailers;
- compostable garment bags;
- dog waste bags;
- custom OEM bag formats.
For EU projects, we prefer to start with the application rather than the word “compostable.”
We normally need to understand:
- Which bag do you need?
- Which country will it enter?
- What thickness is required?
- Is the bag printed?
- Which compostability claim will be used?
- What certification does the buyer need?
- What documentation does the importer or retailer request?
From there, the finished specification is easier to review.
If you need custom size, thickness, colour, printing or packaging, see our OEM compostable bags service.
You can also review our certified compostable bags for common B2B product formats.
Certification and regulatory suitability should always be checked against the finished product, intended use and target market.
FAQ
What is PPWR Article 9?
PPWR Article 9 is the section of Regulation (EU) 2025/40 dealing with compostable packaging.
It defines which packaging must meet compostability requirements, which additional packaging Member States may require to be compostable, and which other biodegradable packaging must follow a material-recycling pathway.
When does PPWR Article 9 apply?
The main requirements in Article 9(1) and Article 9(3) use 12 February 2028 as the key date.
Which packaging must be compostable under PPWR Article 9?
Article 9(1) covers certain permeable tea, coffee and beverage bags, certain soft single-serve beverage units, and sticky labels attached to fruit and vegetables.
These must meet the required industrial-composting pathway by 12 February 2028.
Are compostable produce bags mandatory under PPWR?
Not automatically.
Article 9(1) specifically requires sticky fruit and vegetable labels to meet compostability requirements.
Produce bags may instead fall into the very lightweight or lightweight carrier bag categories, where Member State rules can matter.
Are compostable shopping bags required by PPWR?
Not across the whole EU.
Article 9(2) allows Member States to require very lightweight and lightweight plastic carrier bags to be compostable when the required bio-waste collection and treatment conditions exist.
Are compostable mailers required under Article 9?
No general EU-wide Article 9(1) requirement makes e-commerce mailers compostable.
Other biodegradable packaging generally falls under Article 9(3)’s material-recycling pathway unless a relevant Article 9(2) national rule applies.
What is the difference between Article 9(1), 9(2) and 9(3)?
Article 9(1) creates mandatory EU-wide compostability requirements for specific packaging.
Article 9(2) lets Member States require certain additional packaging to be compostable under defined conditions.
Article 9(3) directs other biodegradable packaging toward material recycling.
Does EN 13432 prove compliance with Article 9?
Not by itself.
EN 13432 remains an important industrial-compostability reference, but the Commission is updating the harmonised standards framework under PPWR Article 9(6).
Read our PPWR vs EN 13432 guide for a detailed explanation.
Can Member States require home-compostable packaging?
In limited cases, yes.
Article 9(1) allows home-compostability requirements where Member States require them. The Commission guidance says these rules should reflect specific local conditions.
Is every biodegradable bag covered by PPWR Article 9?
No.
First determine whether the product qualifies as packaging under PPWR.
A standalone waste-collection bag or dog waste bag may need a different regulatory assessment.
Conclusion
PPWR Article 9 does not say that all packaging should become compostable.
It creates three paths.
Some packaging must meet industrial compostability requirements.
Some packaging may be required to be compostable by individual Member States.
Most other biodegradable packaging must move toward material recycling.
For EU buyers, that means the right order is:
- Identify the product.
- Confirm whether it is packaging.
- Determine the Article 9 pathway.
- Check the target Member State.
- Review the compostability evidence.
- Review the finished-product specification.
- Check technical documentation and claims before production.
Do not begin with the label.
Begin with the use case.
If you are sourcing compostable produce bags, shopping bags or another custom bag format for Europe, send us the target country, intended use, size, thickness, printing requirements and order quantity.
We can then review the product specification and available documentation with you before production.
This article provides general information for packaging buyers and does not constitute legal advice. Requirements can vary according to packaging type, intended use, Member State and later implementing measures.
