Biobased, Biodegradable and Compostable Under the PPWR

Packaging professionals often encounter three distinct terms: biobased, biodegradable and compostable, often used interchangeably in marketing attempts, even though they describe three unrelated properties of a material. As we noted in our article on the Key Milestones of the EU Packaging and Packaging Waste Regulation (PPWR), Regulation (EU) 2025/40 addresses both biobased feedstock and compostability directly, in Articles 8 and 9 respectively. Understanding what each term actually means is now a practical compliance question, not just a labelling nuance.

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Three Properties, Not One Spectrum

According to the European Commission’s policy framework on biobased, biodegradable and compostable plastics, these terms describe independent characteristics of a material rather than points on a single scale.

“Biobased” refers to the origin of the raw material. A plastic is biobased if it is fully or partially derived from biomass (such as corn, sugarcane or cellulose) rather than fossil feedstock. It says nothing about how the material behaves at end of life.
“Biodegradable” refers to a chemical property: the ability of microorganisms to convert a material into water, carbon dioxide and biomass under specific environmental conditions. This property depends on the polymer’s chemical structure, not on where its carbon came from. European Bioplastics underlines: a 100 % biobased plastic can be entirely non-biodegradable, while a 100 % fossil-based plastic can biodegrade.
“Compostable” is essentially a subset of biodegradable. A compostable material biodegrades within a defined timeframe and under the specific conditions of a composting environment, typically an industrial facility, without leaving toxic residue. Compostability is verified against harmonized standards, most notably EN 13432 for industrial composting, which sets thresholds for disintegration (at least 90 % of the material must fragment to under 2 mm within 12 weeks) and biodegradation (at least 90 % conversion to CO₂ within 6 months, benchmarked against a reference material). No harmonized EU standard for home composting currently exists.

A fourth term, “oxo-degradable”, sometimes appears alongside these three but describes a banned category. Oxo-degradable plastics contain additives that cause fragmentation into microplastics rather than genuine biodegradation and have been prohibited under EU law since July 2021.

Biobased Feedstock Under PPWR Article 8

Article 8 of the PPWR does not yet impose binding targets for biobased content in plastic packaging. Instead, it mandates that the European Commission review, by 12 February 2028, the state of technological development and the environmental performance of biobased plastic packaging. Depending on the outcome, the Commission could propose sustainability requirements, targets for increased use or a mechanism allowing biobased content to be partially credited toward the recycled-content targets set under Article 7 for contact-sensitive packaging. The regulation is explicit that biobased feedstock is not a substitute for reuse and recycling, which remain the priority under the EU waste hierarchy and any future rules will require biomass sourcing that avoids deforestation or biodiversity loss.

Compostable Packaging Under PPWR Article 9

Article 9 takes a narrower, more prescriptive approach. From 12 February 2028, a defined list of packaging formats must be industrially compostable, certified to EN 13432 or an equivalent recognized standard. This includes permeable tea and coffee bags, single-serve beverage units and adhesive labels on fruit and vegetables. Member States retain the option to extend this list to further formats where suitable collection and composting infrastructure exists, such as very lightweight plastic carrier bags or coffee capsules and may additionally require home compostability where relevant.

The logic behind this list is practical. These formats are typically contaminated with food or organic residue, making conventional recycling impractical, so routing them to composting alongside food waste is judged to bring a genuine environmental benefit. Outside this defined list, the PPWR does not treat compostability as a general design goal and packaging made from biodegradable polymers that falls outside Article 9’s scope must still meet the standard recyclability requirements under Article 6.

Compostable packaging delivers this benefit only where separate bio-waste collection and industrial composting infrastructure actually exists. Compostable material that ends up in general waste or conventional recycling streams provides no advantage. The Commission was required to request European standardization bodies to develop a harmonized home compostability standard by 12 February 2026, while the revision of EN 13432 for industrial composting must be requested by 12 February 2027, a full year ahead of the Article 9 compliance deadline.

Where the Three Properties Overlap in Practice

In practice, packaging materials fall into distinct combinations of these properties. Bio-PE and bio-PET are biobased but behave identically to their fossil-based counterparts at end of life: fully recyclable, not biodegradable. PLA (polylactic acid) is typically both biobased and industrially compostable, making it a candidate for the Article 9 applications described above, but it is not suitable for mechanical recycling streams designed for conventional plastics. Some biodegradable polymers, meanwhile, are produced from fossil feedstock and are neither biobased nor compostable to the EN 13432 standard. This is precisely the confusion the Commission’s policy framework was designed to address, since a “biodegradable” or “bio-based” claim on packaging communicates nothing reliable about recyclability or compostability unless the specific property and the standard it is measured against are stated.

What This Means for Packaging Producers

Verify which property is actually relevant to the intended application before selecting a biobased, biodegradable or compostable material, since the three do not substitute for one another.
For packaging within the Article 9 scope, confirm compostability through testing against EN 13432 or the forthcoming home-composting standard, rather than relying on supplier claims.
For all other packaging, including biobased and biodegradable materials outside the Article 9 list, plan for compliance with the Article 6 recyclability requirements applying from 12 August 2026.
Track the outcome of the Commission’s Article 8 review, expected by 12 February 2028, as it may introduce sustainability criteria or targets for biobased content.

Conclusion

Biobased, biodegradable and compostable describe three separate material properties. They are not synonyms or even degrees of the same concept. The PPWR reflects this distinction by regulating them separately: Article 8 leaves biobased feedstock to a future review, while Article 9 mandates compostability only for a defined set of applications where it delivers a demonstrable end-of-life benefit. For most packaging, recyclability under Article 6 remains the default requirement, regardless of whether the material happens to be biobased or biodegradable.