If you are sourcing biodegradable or compostable packaging for Europe, one question is becoming more important:
Should this package be recycled or composted after use?
Under PPWR, the answer is not simply:
“If it is biodegradable, compost it.”
That can be wrong.
The PPWR recyclability vs compostability decision depends on the type of packaging, how it is used, and which part of Article 9 applies.
Some packaging has a clear composting route.
Some packaging may be required to be compostable by an EU Member State.
Other biodegradable packaging must follow a material-recycling pathway.
This matters for products such as:
- compostable mailers;
- shopping bags;
- produce bags;
- food packaging;
- tea and coffee packaging;
- other flexible biodegradable packaging.
The material may be compostable.
But the legal end-of-life route may still be recycling.
That is the key point.
For a wider introduction to the regulation, read our PPWR compostable packaging guide.
PPWR Recyclability vs Compostability at a Glance
The easiest way to understand the difference is to look at the three Article 9 routes.
| Packaging situation | Main PPWR route |
|---|---|
| Packaging specifically listed in Article 9(1) | Industrial composting |
| Certain packaging covered by a Member State rule under Article 9(2) | Composting where national conditions are met |
| Other biodegradable packaging | Material recycling under Article 9(3) and Article 6 |
This means compostability is not the default route for every biodegradable package.
In many cases, material recycling remains the PPWR route.
What Does “Recyclability” Mean Under PPWR?
PPWR Article 6 deals with recyclable packaging.
In simple terms, material recycling means the packaging waste is processed so that its material can be used again as raw material for new products.
The PPWR recyclability system includes requirements around:
- design for recycling;
- collection;
- sorting;
- recycling processes;
- recyclability performance;
- recycling at scale.
The detailed requirements are introduced in stages.
The European Commission describes the wider PPWR direction as making packaging recyclable and supporting a more circular use of materials.
Official source: Regulation (EU) 2025/40, Article 6.
What Does “Compostability” Mean Under PPWR?
Composting is a different end-of-life route.
Instead of recovering the packaging material to make another material product, compostable packaging is treated together with organic waste under controlled biological conditions.
Article 9 covers this route.
But it does not give compostability to every packaging format.
It focuses on specific applications where composting can fit the way the product and packaging become waste.
For example, a tea bag often stays together with wet tea leaves after use.
A fruit sticker stays attached to fruit peel.
These are very different waste situations from an e-commerce mailer.
That is why PPWR does not treat all biodegradable packaging in the same way.
Recyclable and Compostable Are Not the Same Claim
These two terms describe different recovery systems.
Recyclable
The aim is to recover the material.
The package enters:
collection → sorting → material recycling → new material
Compostable
The aim is biological treatment.
The package enters:
bio-waste collection → industrial composting → biological breakdown
One route tries to keep the material in a material cycle.
The other treats the packaging together with organic waste.
Both can have a role.
But the right route depends on the application.
Why PPWR Does Not Send All Biodegradable Packaging to Composting
This is one of the most important points in PPWR recyclability vs compostability.
It is easy to think:
biodegradable = compostable = organic waste
PPWR does not use that logic.
Article 9(3) says that packaging outside the specific Article 9(1) and relevant Article 9(2) cases—including packaging made from biodegradable plastic polymers and other biodegradable materials—must, by 12 February 2028, be designed for material recycling in accordance with Article 6.
It must also avoid harming the recyclability of other waste streams.
So biodegradable material alone does not decide the disposal route.
The packaging application comes first.
Official source: Regulation (EU) 2025/40, Article 9(3).
For the full three-path explanation, see our PPWR Article 9 guide.
Article 6 Is the General Recycling Route
Article 6 establishes the general PPWR recyclability framework.
Article 9 then creates specific treatment for compostable packaging.
This relationship matters.
Article 9(1) begins with a derogation from Article 6(1) for the packaging formats that are specifically required to follow the composting route.
In simple English:
For those specific packaging formats, PPWR makes an exception to the normal recyclability route.
That tells us something important about the structure of the Regulation.
Composting is not simply added on top of recycling for every package.
It is a specific route for specific applications.
Article 9(1): When Composting Is the Required Route
Article 9(1) covers specific packaging formats.
By 12 February 2028, these formats must be compatible with composting under industrially controlled conditions.
They include certain:
- permeable tea bags;
- coffee bags;
- other beverage bags;
- soft single-serve units;
- sticky labels attached to fruit and vegetables.
Why these products?
Because the packaging is often difficult to separate from the organic contents after use.
A tea bag is a good example.
The consumer does not normally empty the wet tea leaves and clean the bag for recycling.
The tea and bag stay together.
In that situation, an organic-treatment route can make practical sense.
Article 9(2): When Member States Can Choose Compostability
The second path is more flexible.
Article 9(2) allows EU Member States, under defined conditions, to require some additional packaging to be compostable.
This can include:
- certain non-metal beverage-system units;
- very lightweight plastic carrier bags;
- lightweight plastic carrier bags;
- certain packaging already covered by national compostability rules.
But the local bio-waste system matters.
The Member State needs suitable collection and treatment infrastructure so that compostable packaging can actually enter an organic-waste route.
This is why a bag that makes sense in one country may not make sense in another.
The package does not change.
The waste system does.
Article 9(3): When Material Recycling Is the Route
Article 9(3) is the section many buyers miss.
It covers packaging outside the Article 9(1) and Article 9(2) composting routes.
This includes packaging made from:
- biodegradable plastic polymers;
- other biodegradable materials.
By 12 February 2028, this packaging must be designed for material recycling in accordance with Article 6.
This means the following argument does not work:
“Our packaging is compostable, so recycling rules do not matter.”
For many biodegradable packaging formats, recycling is exactly the route PPWR points toward.
A Simple PPWR End-of-Life Decision Tree
For a B2B packaging project, I would start with these questions.
Step 1 — Is the product packaging?
If no, PPWR packaging rules may not be the main framework.
If yes, continue.
Step 2 — Is it specifically covered by Article 9(1)?
If yes:
Composting route.
Step 3 — Is it a format covered by Article 9(2)?
If yes:
Check the target Member State.
A national compostability requirement may apply.
Step 4 — Is it other biodegradable packaging?
If yes:
Article 9(3) material-recycling route.
Step 5 — Review the finished packaging
Then check:
- material;
- printing;
- adhesives;
- labels;
- additives;
- technical documentation;
- waste-system compatibility.
This order helps avoid choosing the material first and asking about the waste route later.
Why a Compostable Certificate Does Not Decide the PPWR Route
This is another common mistake.
A supplier sends you an EN 13432 certificate.
That can be useful evidence of industrial compostability.
But the certificate does not decide:
- whether Article 9(1) applies;
- whether Article 9(2) applies;
- whether Article 9(3) applies;
- whether Article 6 material recycling is required.
Those are regulatory classification questions.
EN 13432 answers a different question:
Can the packaging meet defined industrial compostability criteria?
PPWR asks:
Which legal end-of-life route applies to this packaging?
That is why the two need to be reviewed together.
For a detailed comparison, read our PPWR vs EN 13432 guide.
Biodegradable Does Not Automatically Mean Compostable
These words are often mixed together.
They should not be.
Biodegradable is a broad term.
It means a material can break down through biological activity under certain conditions.
It does not necessarily tell you:
- where;
- how fast;
- under which treatment system;
- whether the material meets a compostability standard.
Compostable is more specific.
A compostable claim should be linked to defined conditions and technical evidence.
And under PPWR, even a biodegradable or compostable material may still need a material-recycling route depending on the packaging type.
The material property does not replace product classification.
What About Compostable Mailers?
Compostable mailers are one of the clearest examples of this issue.
A standard e-commerce mailer is not one of the packaging formats specifically required to be compostable under Article 9(1).
So simply obtaining EN 13432 evidence does not put the mailer into the mandatory composting route.
Article 9(3) becomes important.
For other biodegradable packaging, PPWR requires a material-recycling design route by 12 February 2028.
This means a mailer buyer should review:
- material composition;
- Article 6;
- Article 9(3);
- printing;
- adhesive;
- release liner;
- recyclability;
- technical documentation;
- end-of-life instructions.
For a full product-specific explanation, read our PPWR compostable mailers guide.
Example: A Compostable E-Commerce Mailer
Suppose you are buying:
350 × 450 mm
60 μm
PBAT/PLA-based film
Green
Two-colour printing
Self-sealing adhesive strip
The supplier provides EN 13432 documentation.
Good.
But you still need to ask:
Question 1
Is the mailer an Article 9(1) packaging format?
No.
Question 2
Is a relevant Article 9(2) Member State rule involved?
Usually not for a standard e-commerce mailer.
Question 3
What does Article 9(3) require?
Review the packaging for material recycling under Article 6.
Question 4
What is the finished construction?
Check:
- film;
- ink;
- masterbatch;
- adhesive;
- release liner.
Now you are reviewing the actual package.
Not only its compostability certificate.
What About Compostable Produce Bags?
Produce bags require more care because different formats can follow different rules.
A sticky label attached to fruit or vegetables falls under Article 9(1).
A thin produce bag does not automatically fall under the same rule.
It may instead be a:
- very lightweight plastic carrier bag;
- lightweight plastic carrier bag.
Then Article 9(2) and national rules can become important.
For example:
12 μm produce bag
is below the 15 μm threshold for a very lightweight plastic carrier bag.
The target country can therefore affect the answer.
For the full classification, read our PPWR compostable produce bags guide.
What About Compostable Shopping Bags?
Shopping bags are another Article 9(2) example.
PPWR defines:
- very lightweight plastic carrier bags: below 15 μm;
- lightweight plastic carrier bags: below 50 μm.
Member States may require qualifying bags to be compostable under the conditions set out in Article 9(2).
But Article 34 also requires Member States to reduce lightweight carrier-bag consumption.
This creates an important point:
A bag can be compostable and still be subject to waste-prevention measures.
Compostability does not mean unlimited use is encouraged.
Read our PPWR compostable shopping bags guide for the full 15 μm, 50 μm and Member State analysis.
What About Food-Waste Bags?
Food-waste liners are often a good functional match for compostability because they can be used to collect organic waste.
But there is another question first.
Is the bag packaging under PPWR?
A standalone bin liner sold for waste collection may not perform the same packaging function as:
- a produce bag;
- a shopping bag;
- a mailer.
So do not automatically use Article 9 simply because a food-waste liner is compostable.
Local:
- bio-waste rules;
- municipal requirements;
- composting-facility acceptance;
may be more important to that product.
Classification comes first.
What About Dog Waste Bags?
The same principle applies.
A dog waste bag may have valid compostability evidence.
But a standalone waste-collection bag may not fall under PPWR’s packaging scope in the same way as an e-commerce mailer.
So:
Compostability ≠ automatic PPWR scope.
This distinction is important for manufacturers and distributors.
Do not add “PPWR compliant” to every compostable product without first checking whether the regulation applies to that product as packaging.
Can Packaging Be Both Recyclable and Compostable?
Technically, a material or package may have more than one tested property.
But from a waste-management point of view, users need a clear disposal route.
A consumer cannot place the same piece of packaging into:
- the recycling bin;
and
- the bio-waste bin
at the same time.
This is why the regulatory and local waste pathway matters.
For B2B packaging design, the more useful question is not:
“Can we claim both?”
It is:
“Which disposal route should the user actually follow?”
Then the artwork and claims should support that route.
Why Mixed Disposal Messages Can Be a Problem
Imagine a package says:
INDUSTRIALLY COMPOSTABLE
and:
RECYCLE WITH PLASTIC FILM
on the same surface.
What should the consumer do?
Even if both statements have some technical basis, unclear disposal instructions can create confusion.
For packaging buyers, I recommend keeping the end-of-life message practical.
First identify:
- Article 9 pathway;
- recycling route;
- target country;
- local collection system.
Then choose the claim.
The disposal instruction should help the user make one correct decision.
Does PPWR Prefer Recycling Over Composting?
A better way to say it is:
PPWR generally builds packaging around material recycling, while creating specific compostability routes for certain applications.
Article 6 provides the general recyclable-packaging framework.
Article 9 creates specific composting exceptions and national options.
Article 9(3) then makes clear that other biodegradable packaging is not automatically moved into composting.
That structure is more useful than saying:
“Recycling is always better.”
or:
“Composting is always greener.”
PPWR does not make the decision through slogans.
It makes it through packaging categories and waste pathways.
Why Waste-System Infrastructure Matters
A compostable package only works as intended if it reaches a suitable treatment system.
That means buyers should check:
- Is bio-waste separately collected?
- Does the local facility accept compostable packaging?
- Is the package industrially compostable or home compostable?
- Will the consumer understand the disposal instructions?
Likewise, recyclable packaging depends on:
- collection;
- sorting;
- recycling technology;
- market infrastructure.
A technically recyclable package that is never collected does not achieve the same practical outcome as one supported by a working recycling system.
This is why PPWR increasingly looks beyond material names.
PPWR Recyclability Timeline
For material-recycling packaging, Article 6 introduces the recyclability system in stages.
Key dates include:
2030
Packaging subject to the recyclability requirements moves into the design-for-recycling performance system.
Packaging needs to meet the required recyclability grades.
2035
Recyclability at scale becomes an additional requirement.
2038
The recyclability-grade threshold becomes stricter.
For biodegradable packaging under Article 9(3), however, 12 February 2028 is already an important date because the packaging must be designed for material recycling in accordance with Article 6.
That earlier Article 9 date is easy to miss.
PPWR Compostability Timeline
The important compostability date is also:
12 February 2028
By that date:
- Article 9(1) packaging needs to meet the industrial-composting route;
- applicable Member State Article 9(2) rules can affect additional packaging;
- Article 9(3) sends other biodegradable packaging toward material recycling.
So 2028 is not simply:
“the year compostable packaging becomes mandatory.”
It is better understood as:
the year PPWR separates the composting and material-recycling pathways more clearly for biodegradable packaging.
Recyclability vs Compostability for Common Bag Types
| Bag type | Main PPWR question |
| Compostable mailer | Usually Article 9(3) / material recycling |
| Very lightweight produce bag | Article 9(2) + Member State rules |
| Lightweight shopping bag | Article 9(2) + Member State rules |
| Fruit/vegetable sticky label | Article 9(1) compostability |
| Standalone food-waste liner | First confirm PPWR packaging scope |
| Dog waste bag | First confirm PPWR packaging scope |
This table is a starting point.
The finished product and target market still need to be checked.
Does EN 13432 Still Matter?
Yes.
EN 13432 remains an important European reference for industrial compostability.
But it should be used for the question it is designed to answer.
It can support evidence that a package meets industrial-compostability criteria.
It does not determine:
- Article 6 classification;
- Article 9 classification;
- Member State rules;
- recyclability route;
- full PPWR technical documentation.
The European Commission is also updating the harmonised standards framework for compostable packaging under PPWR.
So EN 13432 remains relevant.
It is not a complete PPWR decision tool.
Raw Material Evidence vs Finished Packaging
Whatever end-of-life route applies, review the finished package.
Imagine your supplier provides evidence for a base film.
Your finished bag may add:
- colour masterbatch;
- printing ink;
- adhesive;
- label;
- closure;
- different thickness.
These details can affect:
- compostability evidence;
- recyclability;
- sorting;
- material compatibility;
- technical documentation.
A raw-material certificate is useful.
The finished product is what enters the market and the waste stream.
What Should EU Buyers Ask Their Supplier?
For a PPWR recyclability vs compostability review, I would ask these questions.
Product
- What is the package used for?
- Is it packaging under PPWR?
- What happens after use?
Article 9
- Does Article 9(1) apply?
- Could Article 9(2) apply?
- Does Article 9(3) apply?
Material
- What polymers are used?
- What additives are used?
- What ink is used?
- Are there adhesives or labels?
End-of-life
- Industrial composting?
- Home composting?
- Material recycling?
- Which collection stream?
Market
- Which EU Member State?
- What local waste infrastructure exists?
- Are national rules relevant?
Documentation
- Product specification
- Certificate scope
- Test evidence
- Technical documentation
- Conformity information
- Traceability
Do this before final artwork.
A Practical Buyer Decision Example
Imagine two suppliers quote a biodegradable mailer.
Supplier A says:
“Our mailer is EN 13432 certified and compostable.”
Supplier B says:
“Here is the compostability evidence. For your EU e-commerce use, we also need to review Article 9(3), Article 6, the finished film construction, adhesive and target market before confirming the end-of-life claim.”
Supplier B may sound less simple.
But the answer gives you more useful information.
In regulatory sourcing, a simple “yes” is not always the best answer.
Sometimes the correct answer begins with:
“It depends on the application.”
Five Mistakes to Avoid
Mistake 1: “Biodegradable packaging should always be composted.”
No.
Article 9(3) directs other biodegradable packaging toward material recycling.
Mistake 2: “All packaging must be both recyclable and compostable.”
No.
Article 9 creates specific derogations and alternative pathways.
Mistake 3: “EN 13432 decides the PPWR route.”
No.
It supports industrial-compostability assessment.
Mistake 4: “A compostable mailer should go into bio-waste.”
Do not assume this.
Standard mailers are not Article 9(1) mandatory composting formats.
Mistake 5: “The material name decides everything.”
No.
Application, Member State, waste system and finished construction all matter.
How ORIZON Approaches Recyclability vs Compostability Questions
At ORIZON, we manufacture compostable bags for B2B buyers, including importers, distributors, retailers, packaging companies and private-label brands.
We have more than 16 years of manufacturing experience, with a production facility of around 20,000 m², 16 automatic production lines, and monthly capacity of approximately 500 tons.
Our main bag formats include:
- compostable garbage bags;
- compostable shopping bags;
- compostable produce bags;
- compostable mailers;
- compostable garment bags;
- dog waste bags;
- custom OEM formats.
But for an EU project, I do not think the first question should always be:
“Can you make this compostable?”
A better starting point is:
- What is the packaging?
- Where will it be sold?
- What waste stream should it enter?
- What claim will be printed?
- What evidence is available?
Then the material choice can follow.
For e-commerce projects, see our compostable mailer bags.
For custom bag sizes, colours, thicknesses and printing, see our OEM compostable bags.
Certification and regulatory suitability should always be checked against the finished packaging, intended use and target market.
FAQ
What is PPWR recyclability vs compostability?
PPWR recyclability vs compostability refers to the different end-of-life pathways established by Regulation (EU) 2025/40.
Article 6 provides the general material-recycling framework, while Article 9 creates specific compostability routes for certain packaging.
Does PPWR require all packaging to be recyclable?
PPWR establishes a general recyclability framework under Article 6.
However, Article 9 creates derogations for specific packaging that must or may follow a composting route.
Does PPWR require all biodegradable packaging to be compostable?
No.
Article 9(3) specifically requires other biodegradable packaging outside the Article 9(1) and relevant Article 9(2) routes to be designed for material recycling by 12 February 2028.
Which packaging must be compostable under PPWR?
Article 9(1) includes certain permeable tea, coffee and beverage bags, certain soft single-serve units, and sticky labels attached to fruit and vegetables.
Can Member States require other packaging to be compostable?
Yes.
Under Article 9(2), Member States may require certain additional packaging, including qualifying lightweight and very lightweight plastic carrier bags, to be compostable where the stated conditions are met.
Are compostable mailers supposed to be composted under PPWR?
Not automatically.
Standard e-commerce mailers are not Article 9(1) mandatory compostability formats.
Other biodegradable mailer packaging can fall under the Article 9(3) material-recycling route.
Does EN 13432 make packaging exempt from recycling requirements?
Not by itself.
The regulatory route depends on Article 9.
EN 13432 supports industrial-compostability assessment, but it does not determine whether Article 9(1), 9(2) or 9(3) applies.
Can packaging be both recyclable and compostable?
A package may have more than one technical property, but the intended waste-management route should be clear.
Buyers should determine which PPWR pathway and local collection system apply before finalising disposal claims.
What is the key date for biodegradable packaging under Article 9(3)?
The key date is 12 February 2028.
By then, other biodegradable packaging covered by Article 9(3) must be designed for material recycling in accordance with Article 6.
What should an EU buyer check before choosing recycling or composting?
Check the packaging type, Article 9 pathway, target Member State, material structure, end-of-life infrastructure, certification scope, finished-product design and technical documentation.
Conclusion
The PPWR recyclability vs compostability question is not a simple choice between two “green” materials.
It is a packaging-classification question.
PPWR creates a general material-recycling framework under Article 6.
Article 9 then separates biodegradable packaging into different paths.
Some packaging must be compostable.
Some may be required to be compostable by Member States.
Other biodegradable packaging must follow material recycling.
For EU buyers, I suggest this order:
- Identify the packaging.
- Confirm the intended use.
- Check Article 9(1).
- Check Article 9(2).
- If neither applies, review Article 9(3).
- Check Article 6.
- Confirm the target Member State.
- Review the finished product.
- Check certification and technical documents.
- Set the disposal claim last.
Do not start with:
“Which material sounds greener?”
Start with:
“Which waste route actually applies to this package?”
That is a more practical way to make a PPWR packaging decision.
If you are developing a compostable or biodegradable bag project for Europe, send us your target country, bag type, intended use, dimensions, thickness, printing requirements and order quantity.
That gives us a clearer starting point for reviewing the product specification and available documentation.
This article provides general information for B2B packaging buyers and does not constitute legal advice. Requirements can depend on packaging type, intended use, Member State and applicable PPWR implementing measures.
