Bio-based and Compostable Packaging under the PPWR: Opportunities and Limitations

The EU Packaging and Packaging Waste Regulation (PPWR) aims to comprehensively improve the sustainability of packaging. In addition to promoting recycling and reducing harmful substances, bio-based packaging and compostable packaging are also coming into focus. These packaging types offer potential environmental benefits but require clear frameworks to prevent greenwashing and ensure genuine ecological value creation. Articles 8 “Biobased feedstock in plastic packaging” and Article 9 “Compostable packaging” of the PPWR define the requirements and application areas for these materials.

Regulations on bio-based packaging (Art. 8)

Bio-based packaging refers to packaging made entirely or partly from biomass, i.e., from renewable raw materials such as plant starch, sugar cane, or cellulose. The PPWR acknowledges the potential of these materials but also sets strict criteria to ensure their sustainability and promote resource efficiency.

Key aspects of the regulations:

• Review of minimum bio-based plastic content: The PPWR provides for a review by the European Commission by 12 February 2028. Based on this review, targets for promoting the use of bio-based raw materials and corresponding sustainability requirements for plastic packaging may be set in the future.
• No substitute for recycling: It is clarified that the promotion of bio-based plastics must not serve as a substitute for the goals of reuse and recycling. The PPWR continues to prioritise these approaches for waste prevention and resource conservation.
• Sustainable raw material sourcing: The Commission is tasked with adopting rules to ensure that biomass for bio-based packaging originates from sustainable sources and does not lead to environmental problems such as deforestation or biodiversity loss.

Opportunities and challenges

Bio-based packaging can reduce the consumption of fossil resources. However, the challenge lies in ensuring that its production does not compete with food production or cause other ecological issues. Clear definition of sustainability criteria and transparent communication are crucial here.

Requirements for compostable packaging (Art. 9)

Compostable packaging is designed to biodegrade and convert into compost under specific conditions. The PPWR assigns a very specific and limited role to this type of packaging to avoid confusion with other waste streams and contamination of recycling.

Key aspects of the requirements:

• Mandatory compostability: Article 9 of the PPWR stipulates that only a very limited number of packaging types will be mandatory for compostable packaging in industrial composting facilities. These include:
  • Tea bags and coffee pods
  • Small sticky labels for fruit and vegetables
  • Very lightweight plastic carrier bags (as defined in Directive (EU) 2015/720)
• Clear labelling (Art. 13): Compostable packaging must clearly indicate its suitability for industrial composting. This is essential to prevent incorrect disposal into other waste bins and to ensure it actually ends up in the designated composting facilities.
• Certification to standards: The packaging must meet the requirements of the European standard EN 13432 for industrial compostability or equivalent national or international standards recognised as equivalent by the Commission.
• Practical challenges: The biggest challenge with compostable packaging is its separation from other waste. If it ends up in residual waste or recycling, it can disrupt recycling processes and not undergo actual composting. The availability and capacity of industrial composting facilities are also limiting factors.

Strict limitations of use of compostable packaging in accordance with PPWR

The PPWR clearly prioritises reuse and recycling over composting. Mandatory compostability is limited to applications where clean separation from organic residues is difficult or uneconomical, and thus a contamination of other material streams would be imminent. A widespread introduction of compostable packaging is not advisable without adapted collection and recovery systems.

Both bio-based packaging and compostable packaging offer potential for a more sustainable future, but require a precise understanding of PPWR requirements and careful integration into existing waste management systems. For businesses, it is crucial to examine the specific regulations to avoid wrong decisions and promote genuine sustainability.

Stay tuned for the continuation of our blog series, where we will address the important topics of packaging minimisation and re-use under the PPWR.