What Must Be Compostable by 12 February 2028: The Article 9 List

The mandated list is short enough to quote: packaging in the form of permeable bags for tea, coffee or other beverages; the single-serve units used together with those products (the pod and capsule family that brews and discards as one wet unit, within the article's terms); and sticky labels attached to fruit and vegetables. By 12 February 2028 these must be compostable - meeting the compostability requirements the framework sets - in the member states' markets. The list's logic is uniform: items discarded with food waste, at sizes and soil levels that make separate handling absurd.

Everything not on the list is voluntary territory, judged by the biography test and the market's acceptance, not by mandate. This guide fixes the list's edges.

Permeable is the tea bag's defining trait - the bag that steeps is in; the foil freshness pouch around the bags is ordinary packaging under the general duties. Single-serve units are read with their function: the unit that enters the machine and exits with the grounds is the compostable candidate; rigid capsules designed for dedicated collection-and-recycling systems have their own argument, worked in the pods guide. Sticky labels are the produce sticker and its adhesives - the label as applied, not the roll it came from, must compost, which makes the adhesive half the product. Brands should map their portfolios against the three definitions literally, record the mapping, and treat definitional arguments (is our herbal infuser a permeable bag?) as determinations to seek early rather than positions to defend late.

The framework lets member states require compostability for further packaging where their systems make it sensible - the Italian market's long-standing compostable shopper and produce-bag regime is the standing example of a state building on the concept ahead of the Union. Extensions are national law with national dates, and the cross-border producer's obligation is the matrix discipline from the restrictions station: per market, what must be compostable, to what certification, from when. A product compostable-certified for the Union list may still fail a state's extended specification (home versus industrial, thickness, inks) - certification scope, once again, is the operative document.

Conversion lead times in the three formats differ in kind. Tea and coffee bags are a materials-and-machine conversion at the packer (web materials, sealing behaviour, shelf-life validation for the packed product - the compostable web must still protect the leaf for its commercial life). Sticky labels are an adhesive-and-substrate qualification at the label printer, with application and wash-off behaviour in the produce chain to prove. Pods and units are the deepest conversion (materials, machine compatibility, brewing performance). All three share the transition rule: formats placed before the date under the old specification run out under the placing logic; formats placed after it must be the compostable article. Build the changeover plan on the restrictions station's run-out discipline, with the certification lead time as the critical path's first item.

The 2028 date sits in the same quarter as the labelling wave's preparation peak, the artwork changeover programme and the design-for-recycling delegated acts' arrival. Tea, coffee and label converters should therefore read February 2028 as the end of a queue that forms through 2027 - at the certification laboratories, at the compostable-web suppliers, at the packers' conversion slots. The formats are small; the queue is not. Converting in 2027's calm, with testing time in hand, is the discount the calendar offers exactly once.

Notice what the mandate's discipline teaches the voluntary market: three format families, chosen by biography, with a date and a certification - that is the whole intervention. The legislator resisted the expansive version of this policy (compostable as a general plastic strategy) on the infrastructure evidence, and the restraint is the lesson. Businesses mirroring the restraint in their voluntary programmes - few formats, right biographies, proven acceptance - will be aligned with the framework whatever the extensions bring. The expansive version remains available as a marketing strategy; it has never survived contact with a sorting plant.