TL;DR: Claiming “compostable” or “biodegradable” on packaging without market-specific certification documentation exposes your brand to regulatory enforcement, retailer delisting, and consumer protection fines.
For a related specification, compare Bio-Based, Compostable & Recyclable — Material Selection Guide before finalising the packaging brief.
TL;DR: In the EU, packaging making compostability claims must meet EN 13432 and — from 2025 under the PPWR — unverified environmental claims will trigger mandatory substantiation audits with penalties up to 4% of annual turnover.
What Each Major Market Actually Requires — and Where the Standards Diverge #
The compliance picture for sustainable packaging is not uniform. US, EU, and China markets each operate under different certification bodies, different legal triggers, and different enforcement mechanisms. When a brand partner asks us to print “100% compostable” on a mailer bag or “recyclable” on a folding carton, the first question we ask is: which market is this shipping to? The answer changes which documents we need before the job goes to press.
The core standards across markets:
| Market | Compostability Standard | Recyclability Framework | Enforcement Body |
|---|---|---|---|
| EU | EN 13432 / EN 14995 (flexible) | PPWR 2025; Ecolabel reg. | European Commission / national agencies |
| United States | ASTM D6400 (industrial); ASTM D6868 (coated substrates) | FTC Green Guides (16 CFR Part 260) | FTC; state AG offices (CA, NY) |
| China | GB/T 19277.1-2011 (industrial compost); GB/T 38082-2019 (biodegradable plastics) | GB 18455-2010 (recycling labelling) | SAMR / MIIT |
| Australia | AS 4736-2006 (industrial); AS 5810-2010 (home compost) | APCO Responsible Packaging Code | ACCC |
The gap that causes problems most often: ASTM D6400 certification for the US market does not automatically satisfy EN 13432 for EU distribution — the disintegration timeframes, ecotoxicity thresholds, and heavy metal limits are tested under different protocols. We’ve had brand partners arrive with a US-certified compostable film and assume it clears European customs without additional documentation. It doesn’t.
For recyclability claims under the FTC Green Guides, the threshold is that 60% of US consumers must have access to a recycling facility that accepts the material. Printing “recyclable” on a black polypropylene tray that most MRFs cannot sort fails that threshold regardless of the material’s theoretical recyclability.
Where Compliance Documentation Breaks Down — and Why #
The most common failure mode we see is not intentional greenwashing. It’s documentation fragmentation — the brand has a valid certification for the substrate, but the full construction (substrate + adhesive + coating + print ink) has never been tested as an assembly.
EN 13432 and ASTM D6400 both require the complete packaging unit to disintegrate under defined composting conditions, not just the base film. A PLA-coated board that carries a TÜV Austria OK Compost Industrial mark on the base substrate loses that status the moment a UV-cured spot varnish is applied, unless that varnish formulation is explicitly covered in the certification scope. We flag this in our internal material review under what we call the FCM-R composite assessment — any job combining a certified substrate with a secondary coating or adhesive gets a re-evaluation before we confirm the compliance claim on-pack.
The second failure mode is expiry. ISO 14021 — the standard governing self-declared environmental claims — requires that claims remain substantiated. Certifications from third-party bodies like DIN CERTCO, BPI (Biodegradable Products Institute), or TÜV Austria typically carry 2–3 year validity windows with annual surveillance audits. We’ve seen brand partners continue printing certified logos on packaging after the underlying supplier certification lapsed. Under the EU’s Green Claims Directive (proposed 2023, expected enforcement by 2026), that constitutes a misleading commercial practice.
The third failure mode is jurisdictional mismatch, particularly for brands selling across the EU and the UK post-Brexit. The UK retained EN 13432 as a recognized standard but OPSS (Office for Product Safety and Standards) enforces it independently of the CE marking pathway. Dual-market brands need documentation confirming compliance under both frameworks, and the certification body must be recognized in each jurisdiction.
Under REACH Regulation (EC) No 1907/2006, inks and coatings applied to packaging that contacts food must also be assessed for restricted substances — this is separate from compostability certification and runs in parallel. Fluorinated compounds (PFAS) used in some grease-resistant coatings have been under significant regulatory pressure since 2023, and several EU member states have already moved to national restrictions ahead of the EU-wide PFAS restriction entry into force expected in 2026.
Does FSC Certification Count as a Sustainability Claim? #
FSC certification addresses chain-of-custody for responsibly sourced fibre — it does not constitute a compostability or recyclability claim. The two certification streams are independent.
That said, FSC-certified substrates are often a baseline requirement from retail buyers (particularly in the EU and UK) before they will even evaluate a compostability certification. Our paper-based compostable packaging jobs routinely carry both FSC CoC (Chain of Custody) documentation and an EN 13432 test report. For brand partners targeting Costco, Waitrose, or REWE Group, running FSC without compostability certification (or vice versa) typically won’t satisfy the full sustainability brief. The documentation sets complement each other but neither substitutes for the other.
Specification Notes for Brand Partners #
When you brief us on packaging that will carry any environmental claim, we need four things before we can confirm compliance and proceed to sampling.
First, your target market list — not just “global” but the specific countries where this SKU will be sold. The standard that governs in Germany differs from California’s AB 1201 disclosure requirements for compostable plastics.
Second, any existing certification documents for your substrate or film supplier, including the certificate number, issuing body, scope of materials covered, and expiry date. If your supplier cannot provide this, we can refer you to films and boards on our approved materials list that carry current third-party certification.
Third, confirmation of your printing and finishing spec — the claim on a base substrate can be voided by an incompatible coating, adhesive, or laminate. We see this gap in roughly one in five briefs that arrive with a sustainability claim pre-written.
Fourth, your on-pack claim language in draft form. We review this against FTC Green Guides or EN 13432 / PPWR requirements before it goes to artwork approval.
Our typical timeline from complete brief to certified-compliant sample is 18–25 working days, longer if a new substrate requires third-party disintegration testing under ISO 20200.
Frequently Asked Questions #
If my film supplier has ASTM D6400 certification, do I need separate testing for EU distribution?
Yes. ASTM D6400 and EN 13432 use different test protocols, different disintegration timelines (90-day vs. 12-week at 58°C ±2°C), and different heavy metal threshold tables. A certificate from one body does not satisfy the other. You will need a separate EN 13432 test report issued by a notified body recognized by the EU — DIN CERTCO and TÜV Austria are the two most common for flexible films.
What documentation should I keep on file to defend a “recyclable” claim in the US?
The FTC Green Guides (16 CFR Part 260) require that unqualified recyclability claims be supportable by evidence that the material is accepted by recycling programs serving a substantial majority of consumers — the FTC’s threshold is 60% of the population having access. Keep the date-stamped access data, the material acceptance list from your target MRFs, and any How2Recycle label license documentation. Claims made without this file are the primary target of state-level AG enforcement in California and New York.
Does printing a compostability logo on packaging require a license?
It depends on which logo. The BPI logo, TÜV Austria OK Compost marks, and DIN CERTCO seedling logo all require active license agreements that are tied to a specific certified product. You cannot print these marks based on a supplier’s certification — the brand or brand’s packaging manufacturer must hold the license for that specific packaging construction. We assist partners with this application process as part of our FCM-R composite assessment workflow, but the license holder of record must be the brand entity.
Our packaging is PLA-lined board. Does the PLA liner affect paper recyclability claims?
Yes, and this is a real problem in practice. PLA-lined boards are typically not accepted in standard paper recycling streams because PLA does not repulp cleanly at the temperatures used in most paper mills. A board construction with PLA lining should not carry an unqualified “recyclable” claim for paper recycling. It may qualify for industrial composting claims if the full construction passes EN 13432 or ASTM D6400. Clarity on this point in your on-pack language matters — vague language here is exactly what the EU Green Claims Directive targets.
How often do compostability certifications need to be renewed?
Certification renewal cycles vary by body: TÜV Austria OK Compost Industrial marks run on a 2-year cycle with annual product surveillance; BPI certification in the US requires annual renewal with re-testing if formulation changes occur; DIN CERTCO operates on a 3-year cycle with annual audits. Any formulation change to the certified construction — a new adhesive, a different ink system, a coating reformulation — triggers a reassessment regardless of where you are in the renewal cycle.
Planning a packaging project? Contact our team to request a complimentary specification review and sample quote.
