A marketing brief arrives asking for "100% eco-friendly, biodegradable" printed on the new burger box. In the EU that wording has been off the table since 27 September 2026, in the UK it invites a regulator's question you cannot answer, and in the US it fails the FTC's test for unqualified claims. This guide explains recyclable vs compostable packaging (and where "biodegradable" fits), what each claim requires as evidence, and how to word claims on printed packaging so they survive scrutiny in Germany, Austria, the Netherlands, the UK and the US.
It covers terminology and claim rules. For which coatings make a paper item recyclable or compostable in the first place, see barrier coatings for paper packaging.
Recyclable vs compostable packaging: what is the difference?
Recyclable packaging is designed to be collected, sorted and reprocessed into new material, so its fibre or polymer re-enters production. Compostable packaging is designed to break down into water, carbon dioxide and biomass in a composting process within a defined time, leaving no harmful residue. The first keeps material in use; the second returns it to soil, and only works where the item actually reaches a suitable composting process.
Neither is better in the abstract. Which claim is credible for a given item depends on three things: the collection system where it is thrown away, how much food residue it carries, and whether test evidence exists for that exact construction.
| Term | What it means in practice | What backs the claim | Main risk |
|---|---|---|---|
| Recyclable | Collected, sorted and reprocessed in existing streams at scale | Design-for-recycling assessment, repulpability or sorting tests, evidence that collection exists for the target market | Claiming recyclability where collection or reprocessing is not available to most consumers |
| Industrially compostable | Breaks down in managed industrial composting (higher, controlled temperatures) | Certification to EN 13432 (EU) or ASTM D6400 / D6868 (US), e.g. via BPI or a European scheme | Many areas do not accept packaging in organic waste; consumers put it in home compost or litter |
| Home compostable | Breaks down in a garden compost heap at ambient temperature | Private certification (e.g. "OK compost HOME"); EN 17427 exists only for carrier bags | No harmonised EU standard for packaging generally; slower, less predictable conditions |
| Biodegradable | Broken down by micro-organisms at some point, in some environment | Almost nothing meaningful without a stated environment and time frame | Treated as a generic or misleading claim under EU, UK and US rules |
| Recycled content | Contains a stated share of recycled material | Supplier documentation, chain-of-custody records | Overstating the percentage or confusing pre- and post-consumer content |
Why is "biodegradable" a problem claim?
Because almost every organic material biodegrades eventually, the word on its own tells a buyer nothing about where, how fast or under what conditions. Regulators in the EU, UK and US treat an unqualified "biodegradable" as vague at best and misleading at worst, and the EU now names it as an example of a prohibited generic claim unless strict conditions are met.
"Oxo-degradable" is a separate and stronger warning: oxo-degradable plastics have been banned in the EU under the Single-Use Plastics Directive (EU) 2019/904 since 3 July 2021. If a supplier offers an "oxo-biodegradable" bag or film for an EU order, decline it.
For packaging buyers the practical rule is simple. Do not print "biodegradable". If the material is certified compostable, say "compostable" with the certification and the conditions; if it is recyclable, say "recyclable" with qualification where needed.
Industrial vs home composting: which standards apply?
Industrial composting standards test packaging under managed conditions at higher temperatures than a garden heap; home-compost certifications test at ambient temperature over a longer period. A product certified to an industrial standard should not be described as home compostable, and the reverse claim needs its own certificate.
Industrial composting standards
- EN 13432 (EU): the reference standard for industrially compostable packaging. It sets requirements for disintegration, biodegradation, ecotoxicity and limits on certain substances, assessed on the finished packaging construction, including inks and coatings.
- ASTM D6400 (US): specification for plastics designed to be composted in municipal or industrial facilities.
- ASTM D6868 (US): specification for biodegradable plastic coatings or layers on paper and other compostable substrates, which is the one relevant to PLA- or dispersion-coated paper and board.
- BPI certification (US): the Biodegradable Products Institute certifies products against ASTM standards and applies a fluorine limit (no more than 100 ppm total organic fluorine), which links compostability to PFAS-free construction. See PFAS-free food packaging.
Home composting
There is no harmonised EU standard for home-compostable packaging in general. EN 17427 covers home-compostable carrier bags only. "OK compost HOME" is a private certification scheme, widely recognised by retailers, but a private label rather than a legal standard. Some national and US state rules add their own labelling expectations, so a home-compost claim acceptable in one market can be incomplete in another.
Certification covers the whole construction
A compostable certificate for a coating or a base paper does not automatically cover your printed item. Ink coverage, adhesives, windows and board thickness can all affect the outcome. Ask your supplier whether the certificate relates to the exact construction you are ordering, or to a component only.
Does the EU still allow compostable packaging under the PPWR?
Yes, but compostability is required only for a narrow list of items. Under Article 9 of the Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR), packaging that must be compostable is limited to tea and coffee bags and pods, sticky labels attached to fruit and vegetables and, where a Member State chooses, very lightweight and lightweight plastic carrier bags. All other packaging, compostable or not, must be recyclable. The PPWR has applied generally since 12 August 2026, with recyclability performance grades taking effect from 1 January 2030.
For a takeaway box, cup or wrap destined for Germany, Austria or the Netherlands, this shifts the design target clearly towards recyclability. A compostable coating may still be used, but the item will need to meet recyclability requirements too, and the PPWR's harmonised labelling rules (expected to apply from 12 August 2028 at the earliest, pending an implementing act) will require compostable packaging to state that it is not for home composting. Treat the exact labelling date as provisional. The full regulation is explained in our PPWR guide.
What changed for green claims in the EU on 27 September 2026?
Directive (EU) 2024/825, the Empowering Consumers for the Green Transition Directive, has applied in EU Member States since 27 September 2026. It bans generic environmental claims such as "eco-friendly", "green", "environmentally friendly" or "biodegradable" unless the trader can demonstrate recognised excellent environmental performance relevant to the claim. Sustainability labels must be based on a certification scheme or established by public authorities, and claims that a product is "climate neutral" on the basis of offsetting are banned.
What this means on printed packaging:
- Generic badges ("eco", "planet-friendly", a green leaf with no explanation) are high-risk. Remove them from artwork rather than defend them.
- Self-created logos that look like certification marks are effectively prohibited. A label needs a certification scheme or public authority behind it.
- Claims must be specific to the part of the product they describe. "Recyclable box (lid and base)" is clearer than "sustainable packaging".
The separate Green Claims Directive proposal, which would have added pre-approval of claims, has been on hold since June 2025. Directive 2024/825 is implemented through national consumer law, so enforcement routes and practice differ between Germany, Austria and the Netherlands. Confirm wording with your legal or compliance adviser for each market.
What rules apply to packaging claims in the UK?
In the UK, environmental claims are assessed against the CMA's Green Claims Code: claims must be truthful and accurate, clear and unambiguous, must not omit or hide important information, must make fair comparisons, consider the full life cycle and be substantiated. Under the Digital Markets, Competition and Consumers Act 2024, the CMA has been able to impose fines of up to 10 % of global turnover directly since April 2025, without going to court first.
Two UK specifics affect printed packaging. First, mandatory recyclability labelling ("Recycle" / "Do not recycle") was removed from the packaging EPR regulations pending alignment, and no new date has been set; the OPRL label remains a voluntary scheme. Second, England's single-use plastics bans cover certain plastic-coated paper items such as plates and bowls, so describing a PE-coated product as "plastic-free" would be both wrong and risky. The wider UK regime is covered in UK packaging regulations.
What rules apply in the US?
In the US, the FTC's Green Guides (16 CFR Part 260, last revised in 2012 and under review since December 2022) remain the federal reference. An unqualified "recyclable" claim is only acceptable where recycling facilities are available to a substantial majority of consumers or communities where the item is sold, which the FTC sets at 60 %. Below that, the claim must be qualified, for example "Recyclable only in the few communities that accept coated paper cups".
State law adds further layers:
- California SB 343 restricts use of the chasing-arrows symbol and "recyclable" claims on packaging that does not meet California's criteria for collection and sorting. Its restrictions were due to apply from 4 October 2026, but on 14 July 2026 a federal court (S.D. Cal., California League of Food Producers v. Bonta) preliminarily enjoined the state from enforcing SB 343 against any business while the case continues; check the current status before printing for California.
- California AB 1201 and compostable labelling laws in Washington and Colorado set rules on how compostable products may be marked, including requirements for certification and distinguishing features. From 1 January 2026 AB 1201 also requires compostable-labelled products to be allowed inputs under the USDA National Organic Program; CalRecycle has postponed this requirement to 30 June 2027 for products containing synthetic substances such as PLA or PHA that otherwise meet the rules (renewals capped at 1 January 2031). Confirm the current position with your compliance adviser.
- BPI-certified compostable items must meet the fluorine limit noted above, which interacts with state PFAS bans covered in US foodservice packaging regulations.
How should environmental claims be worded on printed packaging?
Make every claim specific, qualified where needed, and backed by a document you could hand to a regulator tomorrow. Name the material and the component, state the condition (recycling stream, composting type), and reference the certification by its scheme name and licence number where one exists.
| Weak or risky wording | Better wording (if evidenced) | Evidence to keep on file |
|---|---|---|
| Eco-friendly packaging | Box made from paperboard. Recycle with paper and card where accepted. | Material specification; design-for-recycling assessment; local collection evidence |
| 100% biodegradable | Industrially compostable to EN 13432. Not suitable for home composting. | Certificate covering the exact printed construction |
| Plastic-free cup | Paper cup with a water-based barrier lining | Supplier declaration of lining composition |
| Sustainable packaging | Made with 70 % recycled fibre | Supplier recycled-content statement and chain-of-custody records |
| Green leaf icon with no text | Remove, or replace with a certified label used under licence | Licence agreement for the label |
| Recyclable (US, coated cup) | Recyclable only where coated paper cups are accepted. Check locally. | Evidence of access rates for the target market |
Practical rules for artwork:
- Separate components. A pizza box, a PE-lined cup and a windowed bag each have parts that behave differently in recycling. Say which part a claim applies to.
- Avoid comparatives you cannot prove ("50% less plastic") unless you hold a documented baseline and calculation.
- Keep claims out of the food-contact print zone where possible and away from legally required markings such as the "Plastic in product" marking on PE-lined cups under Implementing Regulation (EU) 2020/2151.
- For multi-market artwork, design to the strictest market. A claim acceptable in one country but not in another forces separate print versions and higher costs; see packaging cost drivers.
- Build a claim file per SKU: the claim text, the evidence, the date checked and the markets it covers. Re-check when the material or market changes.
Product-specific answers are covered in dedicated articles: whether greaseproof paper is recyclable or compostable, whether pizza boxes can be recycled, paper cup linings, PET vs PP vs rPET vs PLA cups and recyclable mono-material pouches.
Can we print FSC or PEFC logos on our packaging?
Only if the chain of custody is certified and you hold, or your supply chain provides, the right to use the trademark. FSC and PEFC on-product labels require chain-of-custody certification for each company that takes ownership of the material, plus a trademark licence and label approval through the scheme. Without that, printing the logo, or wording like "made from FSC paper", is a misuse of a protected mark and, under EU rules, a sustainability label without a valid scheme behind it.
If certified material matters to your brand, raise it at enquiry stage so the supplier can confirm what it can and cannot offer on that specific order and how labels would be approved. Do not assume any supplier, including 9 Packaging, holds a particular certification unless it is confirmed in writing for your order.
Recyclable or compostable: which should you specify?
For most printed foodservice and retail packaging sold in the EU, UK and US, recyclable paper-based construction is the safer default: it aligns with PPWR Article 9, fits existing collection, and is easier to substantiate. Compostable construction makes sense mainly where food contamination prevents recycling and the item demonstrably goes to industrial composting, such as closed venues or stadiums with organic waste collection, or where a specific contract or local scheme requires it.
Decision rules:
- Item heavily soiled with food and collected with food waste in a closed system: compostable can be justified, with certification and clear disposal instructions.
- Item sold to the public in the EU for general takeaway: design for recyclability first; check the PPWR position for your format.
- Item with a plastic layer: claims must reflect that layer; a "plastic-free" claim is not available.
- Market list includes California: check SB 343 status before printing chasing arrows.
- No certificate or test report for the exact construction: make no compostability or recyclability claim beyond a factual material description.
What to prepare before briefing a supplier
Bring the claim question to the supplier at the start, not after artwork approval. Useful inputs:
- Target markets (country by country, including US states).
- The exact claim text marketing wants to print, and where on the pack.
- Required end-of-life route (recycling, industrial composting) and any customer or tender requirement.
- Certifications you expect to reference, and who will hold the licence.
- Food type, temperature and grease exposure, which drive coating choice and therefore the claim.
These inputs fit into a standard quotation request; see the packaging RFQ guide. For product-level options, start from the hubs for custom printed greaseproof paper, custom printed pizza boxes, custom printed paper cups and custom printed stand-up pouches, or send your draft claim wording with your enquiry via contact so material and claim can be reviewed together at quotation.