Two enforcement frameworks converged in 2026 to make unsubstantiated compostability and biodegradability claims on packaging a material legal risk rather than a reputational one. The EU’s Packaging and Packaging Waste Regulation (PPWR), applying from 12 August 2026, restricts compostable packaging claims to formats that comply with recognised standards and bans claims on formats outside the designated compostable applications without evidence of compliance.
In the UK, the Digital Markets, Competition and Consumers Act 2024 gave the Competition and Markets Authority the power to impose fines of up to 10% of global annual turnover for misleading environmental claims without going to court. Trading Standards data suggests more than 60% of biodegradable products audited in the UK lack credible evidence of biodegradability. The gap between what brands are claiming and what enforcement expects them to prove has closed.
Verifying a compostability claim correctly means demonstrating compliance with a recognised standard, not relying on a supplier’s verbal assurance or a general material description. In Europe, the primary standard is EN 13432. In the UK, the equivalent is BS EN 13432. Certification to either standard must be obtained from an accredited third-party body. It cannot be self-declared.
What EN 13432 Verification Requires
EN 13432 sets four criteria that must be satisfied simultaneously for a packaging material to achieve certification. Biodegradability requires at least 90% of the material to degrade into carbon dioxide within six months under controlled composting conditions at 58 degrees Celsius.
Disintegration requires that no more than 10% of the original material remains in fragments larger than 2mm after 12 weeks. The material must demonstrate no negative effect on the composting process itself. Finally, the compost produced must be non-toxic and must support normal plant germination and growth.
All four criteria apply to the complete label or packaging construction and not to the primary material in isolation. A compostable facestock combined with a conventional adhesive or synthetic ink does not meet EN 13432 as a whole, regardless of the facestock’s individual performance. Certification must cover the entire construction including facestock, adhesive, inks, and any laminate or overcoat.
The Documentation That Defends a Claim
The minimum documentation required to defend a compostability claim under both PPWR and CMA enforcement is: a valid certificate of conformity from an accredited body (TÜV Austria, DIN CERTCO, or BPI are among those recognised); independent laboratory test reports demonstrating EN 13432 compliance for the specific construction; a bill of materials covering every layer of the construction; and evidence that the certified construction matches the material currently in production.
Certificates with no corresponding production record do not constitute a defensible evidence base. Any brand using compostability or biodegradability language on packaging in 2026 without this documentation is carrying an enforcement exposure that the new legal framework has the tools to reach.