Packaging regulation is now a sourcing requirement, not a final artwork check. But the wrong shortcut is just as costly as doing nothing: a compostability certificate does not automatically prove that a package is lawful in every market, accepted by a local collection program, or compliant with every part of a packaging regulation.
This guide gives procurement, compliance and private-label teams a practical way to compare the European Union’s Packaging and Packaging Waste Regulation (PPWR) with California’s SB 54 producer-responsibility program. It is a preparation framework, not legal advice.
Executive summary for packaging buyers
- EU PPWR: Regulation (EU) 2025/40 entered into force on 11 February 2025 and generally applies from 12 August 2026. It covers packaging placed on the EU market, including imported packaging.
- California SB 54: this is an extended producer responsibility program for covered single-use packaging and plastic food-service ware. Producer identification, registration or exemption, reporting and the covered-material category all matter.
- Product evidence: build a controlled file for each SKU. Do not rely on a supplier logo strip or a certificate for a base resin that may not cover the finished construction.
- Claims versus permission: proof of compostability supports a claim within its scope. It does not, by itself, make a packaging use legal or accepted by a collection system.
EU PPWR in 2026: what changed
The PPWR creates a directly applicable EU framework for packaging and packaging waste. The European Commission states that it covers all packaging regardless of material or origin and introduces requirements across manufacturing, composition, prevention, reuse, recoverability, labelling and waste management.
For an importer, distributor or brand owner, the first question is not “Is this bag compostable?” It is “What is the exact packaging format, what does it contain, where will it be sold, and what is our economic-operator role?” Those facts determine which provisions and evidence must be reviewed.
Do not turn EN 13432 into a universal PPWR badge
EN 13432 is an important European standard used to support industrial-compostability claims for packaging. It is not a certificate of full PPWR compliance. A complete review can also involve packaging minimisation, recyclability, substances of concern, labelling, technical documentation and operator obligations.
Certificate scope matters. Confirm whether the named product covers the finished bag or film, the formulation and gauge, and any inks, adhesives or labels. If the evidence only identifies a resin, ask how the converted construction is covered.
The minimum evidence file to request
| File item | What the buyer should verify |
|---|---|
| Product specification | SKU, dimensions, gauge, formulation, colours, inks, adhesives, closures and intended use. |
| Certificate or test report | Holder, issuer, standard, product/scope, current status and whether the finished construction is covered. |
| Substances evidence | Formulation-specific declarations and supporting basis for the relevant application, especially food contact. |
| Artwork file | Approved environmental claims, marks, disposal wording, language and version control. |
| Traceability | How the production batch links back to the agreed specification and evidence set. |
| Operator documents | Technical and conformity records required for the importer, manufacturer or other responsible operator. |
PFAS: focus on food-contact packaging and evidence
The European Commission specifically identifies PPWR restrictions on PFAS in food-contact packaging when specified thresholds are exceeded. That is narrower and more useful than a generic “PFAS-free” badge across an entire catalogue.
Tell the supplier whether the packaging will contact dry, wet, fatty, acidic, hot or frozen food. Ask for a declaration tied to the exact formulation and construction, plus the basis used to support it. Food-contact compliance and compostability are separate evidence tracks; one does not establish the other.
California SB 54: an EPR program, not just a material rule
California’s SB 54 establishes an extended producer responsibility program for covered single-use packaging and plastic food-service ware. CalRecycle’s 2026 guidance says producers must apply to participate in the approved producer responsibility organisation plan, apply as an independent producer, or obtain a small-producer exemption when eligible.
The practical task is to identify the responsible producer and the covered material category before making supply decisions. A package described as compostable is not automatically outside the program. Check CalRecycle’s current covered-material category list, exclusions and guidance for the exact item.
Published SB 54 program targets
| Date | California program target highlighted by CalRecycle |
|---|---|
| 1 January 2027 | 10% reduction in single-use plastic. |
| 1 January 2028 | 30% of single-use plastic recycled. |
| 1 January 2030 | 20% reduction and 40% recycling. |
| 1 January 2032 | 25% reduction, 65% recycling, and 100% of covered single-use packaging and plastic food-service ware recyclable or compostable. |
These are program-level targets. They are not a promise that every product carrying a compostable mark qualifies for every use or end market.
Do not confuse SB 54 with California’s checkout-bag law
SB 54 is the packaging EPR framework. SB 1053 is a different law addressing carryout bags at covered stores. From 1 January 2026, SB 1053 generally prohibits those stores from providing, distributing or selling carryout bags at the point of sale, with qualifying recycled paper bags and specified exclusions treated separately. The earlier compostable-bag point-of-sale allowance was in a provision repealed for 2026.
For bag sourcing, document whether the item is a point-of-sale carryout bag, a precheckout produce or food bag, a nonhandled protection bag, a liner, a waste bag or another format. See the California SB 1053 scope guide and confirm uncertain applications with California counsel or the local authority.
A cross-market sourcing brief that gets a useful answer
- Destination: country, state and city where the packaging will be placed on the market.
- Operator and channel: importer, brand owner, distributor or retailer; retail, food service, e-commerce or industrial use.
- Exact application: what the package contains, where it is handed to the user and the expected disposal route.
- Construction: dimensions, gauge, layers, resin blend, print, adhesive, closure and secondary packaging.
- Performance: load, seal, puncture, barrier, temperature, shelf-life and machinery requirements.
- Claims: the precise wording and mark you intend to print — not simply “eco-friendly”.
- Evidence: required standards, customer audit documents, declarations, traceability and approval owners.
- Commercials: annual volume, target order size, delivery location and launch date.
This brief lets a supplier match a viable construction and disclose gaps before sampling. It also reduces the risk of approving attractive artwork before the evidence and legal route are settled.
How to verify a supplier response
- Match the certificate holder and manufacturing entity to the proposed supply chain.
- Search the issuer’s public registry when one is available; do not rely only on a PDF or badge image.
- Compare the exact product name, formulation and construction with the quotation and sample.
- Check validity and renewal status, then record the version reviewed.
- Ask what changes — gauge, colour, ink, adhesive or dimensions — would move the product outside the evidence scope.
- Keep a written gap list for anything that still depends on testing, certification or legal review.
Use Esinle’s certification-scope page to understand the evidence categories, then request current files for the exact shortlisted SKU. For EU work, the PPWR procurement navigator converts the same approach into a short preparation check.
Primary sources to monitor
- European Commission — Packaging waste and PPWR overview
- European Commission — PPWR FAQ
- EUR-Lex — Regulation (EU) 2025/40
- CalRecycle — SB 54 program
- CalRecycle — Producer guidance
- California Legislative Information — SB 1053 text
Last editorial review: 10 September 2026. Regulations and implementation guidance change; re-check the primary sources and obtain professional advice for the exact product and market.