Zhongxin supplies international packaging groups and serves end-use applications for leading foodservice, retail, and supermarket brands.
From 27 September 2026, environmental claims on packaging sold into the EU and EEA must be specific, substantiated and backed by a recognised certification scheme — generic wording such as “eco-friendly”, “green” or “climate neutral” is no longer safe on artwork. For buyers of bagasse and molded fiber foodservice packaging, that changes two things at once: which sentences survive on your carton or clamshell print, and which documents your manufacturer has to hand over before you approve a purchase order.
Last updated: September 2026. This page is a procurement summary of publicly available EU guidance, not legal advice, and it does not reproduce statutory text verbatim. Confirm the wording that applies in your destination market with your own compliance adviser.
If your packaging says something environmental, that statement now needs three things: it must name a specific, verifiable property; the evidence must be available to the brand at the moment of printing, not behind a QR code; and if the artwork shows a certification mark, the mark must correspond to the exact product and certificate holder. Terms tied to a recognised standard — “industrially compostable to EN 13432”, “home compostable”, “PFAS-free with test report” — remain usable when the underlying certificate or report covers the SKU you are buying. Umbrella wording — “eco-friendly”, “sustainable”, “green”, “biodegradable” on its own, “carbon neutral” bought through offsets — is the wording that creates exposure.
The rules come from Directive (EU) 2024/825, the “Empowering Consumers for the Green Transition” directive, which amends the Unfair Commercial Practices Directive. Member states had to transpose it by 27 March 2026, and it applies from 27 September 2026. The European Commission describes the outcome as clearer, more credible information for buyers on circular-economy claims. Legal and enforcement summaries published before the application date converge on four operative points:
The scope point matters for importers: the requirements are described as applying to traders in the EU and EEA, and to non-EU companies selling products to EU or EEA consumers. In practice the party whose brand appears on the packaging carries the consumer-facing exposure, which is exactly why EU customers increasingly ask for the paperwork before they confirm an order.
| Wording on artwork | Status | Why | Evidence to hold before approval |
|---|---|---|---|
| “Industrially compostable — EN 13432” | Usable when the SKU is covered | Names a specific standard and a specific disposal route | Certificate for the certified product family, plus the register entry for the item you buy |
| “Home compostable — OK compost HOME” | Usable only with a home-compost result | Industrial compostability does not prove home compostability | Separate home-compost certificate; note that licence codes differ by programme |
| “BPI Certified” mark | Usable only for listed items | BPI publishes certified items per SKU under one licence number | Directory listing showing your item under the supplier’s licence |
| “PFAS-free” / “no added fluorine-based polymers” | Usable when tested | A performance claim tied to a measurable property | Test report with method, detection limit and the exact item code; total fluorine result |
| “Food contact compliant — EU 10/2004 / 1935/2004” | Usable when documented | Compliance statement, not a green claim | Declaration of Compliance for the article and its layers |
| “Eco-friendly”, “green”, “sustainable”, “planet-friendly” | Do not print | Generic environmental claim without recognised performance | None of the usual factory paperwork substantiates this wording |
| “Biodegradable” on its own | Do not print unqualified | Describes a chemical property, says nothing about conditions or timescale | Would still need a standard, a medium and a timeframe |
| “Carbon neutral” / “climate neutral” | Avoid | Offset-based neutrality claims are restricted | Only defensible with a verified reduction plan, not offsets |
| “100% compostable in your garden” | Do not print | Consumer-level disposal promise, hard to substantiate | Home-compost certification at the claimed conditions |
The most common artwork failure is treating a certificate as a company-level badge. In molded fiber tableware, certification is granted in narrow dimensions, and a claim printed on your brand has to sit inside those dimensions.
Three examples from our own documentation make the pattern concrete. Our BPI registration runs as one licence number for the group, with certified items published individually in the BPI certified products directory — the public list is item-by-item, so a “BPI Certified” claim maps to an SKU, not to a factory. Our OK compost registrations are held as separate certificates per product family, and the logo artwork itself carries a licence code (S0909) that identifies the registered holder. And when our Thailand plant was approved to use the USDA Certified Biobased Product label in August 2025, the notice named one specific product line at 99% biobased content, with the label void if the formulation changes or if the minimum content requirement is revised.
| Scheme | Where buyers use it | Unit the certificate is granted in | What to verify before printing |
|---|---|---|---|
| BPI Certified (ASTM D6400 / D6868) | US and Canada | Individual listed item under a company licence number | Your item appears in the public directory under that licence |
| OK compost INDUSTRIAL / HOME (EN 13432) | EU and UK | Product family, separated by industrial and home compost result | The programme you cite matches the wording on the artwork |
| USDA Certified Biobased Product | US | Named product with a stated biobased percentage | Reformulation or a revised minimum can void label use |
| Food-contact DoC (EC 1935/2004, 2023/2006, EU 10/2011 where relevant) | EU and EEA | Material/article and its layers, per supplier declaration | See our guide to which declaration each market requires |
| ABA AS 4736 / AS 5810 | Australia and New Zealand | Per product family, one-year renewable registration | Check the current registration year, not an old PDF |
Buyers who ask for this pack in the RFQ stage rather than after the first production run avoid most of the cost. Ask the manufacturer for:
Our internal teams assemble this pack for private-label programs alongside the artwork checklist in custom printed bagasse tableware for private-label buyers, and the verification routes are covered in how to verify a BPI certificate through product listings and SKU matching.
The manufacturer can prove what a product is made of and what it was tested to. Only the brand owner decides what the packaging says. That split is why the same order can be compliant in one market and not in another: a US buyer printing “BPI Certified” against a listed SKU is inside the scheme, while an EU buyer printing “100% biodegradable — returns to nature” on the same tray is making a generic claim with no recognised substantiation. Importers who place packaging on the EU market also carry the separate PPWR obligations, including material-composition and waste-sorting labelling that phases in from August 2026 and compostability standard requirements expected by February 2028. For the wider certification picture see our compostable packaging certification guide: EN 13432 vs BPI vs home compost.
If you are sourcing bagasse tableware in bulk for an EU or UK program and want the claim matrix prepared against your item codes, send us your artwork wording and target market — we will tell you which lines our documentation supports and which ones you need to drop before printing.
No, not as a standalone word. Generic environmental claims such as “eco-friendly”, “green” or “sustainable” are prohibited unless the trader can show recognised environmental performance relevant to that claim. The practical route is to replace the generic word with a specific, provable statement — for example “industrially compostable to EN 13432, certificate held for this product family”.
Yes, when the certificate covers the item you are buying and the wording matches the composting route. Industrial compostability under EN 13432 or BPI does not support a home-compost claim, and it does not support “biodegrades in soil” or “breaks down in the ocean”. Keep the qualifier in the sentence: “industrially compostable” or “home compostable”, not “compostable” alone.
Not automatically. Certification marks are licensed, and the licence runs to the certificate holder and the certified items listed in the public directory. Ask the certificate holder in writing whether a third-party brand may place the mark, and under whose licence number, before the mark enters your artwork.
Summaries of the directive indicate that pointing to further information through a link or QR code is no longer sufficient on its own for substantiating a green claim. The claim itself needs to be specific on the pack, with the underlying evidence held by the trader at the time of printing.
The restrictions sit in consumer-protection law covering commercial practices toward consumers, enforced through national rules that member states had to adopt by March 2026. Whether a specific business-to-business supply relationship is in scope depends on the national law of the market you sell into. In practice the exposure lands on the party whose brand and artwork reach consumers, so confirm the position with your own compliance adviser.
A claim substantiation pack: certificate copies with the public register entry and validity dates, a scope statement in the certificate’s own dimensions (site, formula, colour, product category, thickness limit), test reports behind any performance wording, written mark-usage terms, a per-SKU claim matrix, and change-control commitments. Our food packaging range pages list the documentation we can issue per item.
