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Compostable

We all want our packaging to be good (or at least not bad) for the environment. One approach is to use compostable packaging materials. Unfortunately, that’s easier said than done. There are federal – and sometimes state – requirements that you must meet in order to say that your packaging is compostable.

What is composting?

According to the Environmental Protection Agency (EPA), composting is “the controlled, aerobic (oxygen-required) biological decomposition of organic materials by microorganisms.”¹ Essentially, it’s nature’s way of recycling.

It's important to note two things about that definition. First, it is a controlled activity. Second, it works on organic materials (that’s “organic” as in plant-based, not necessarily “organic” as in without synthetics or pesticides).

What can be composted?

Almost any type of plant matter can be composted, including food scraps, grass clippings, tree leaves, etc. Some materials made from plant matter (such as paper, cardboard, and bio-plastics) can be composted, but they may require special treatment, which is only found in commercial composting operations.

One additional factor in considering composting is that while the material may break down if there are toxins or harmful ingredients in the starting material, they will end up in the final soil or mulch and could be detrimental to the environment or affect plants grown in the medium.

Federal Regulations

Federal regulations covering “compostable” claims on packaging are from the Federal Trade Commission. They prohibit any type of deceptive claims that the package (or product) is compostable.

In other words, if you say it’s compostable, it must actually be compostable. You must have competent and reliable scientific evidence that all the materials in the item will break down into, or become part of, usable compost in a safe and timely manner (about the same time as it would take in an appropriate composting facility or a home compost pile or device).

When determining whether your package is compostable, remember to consider not only the paper, paperboard, or box, but also the ink and any adhesives used.

What would make a “compostable” claim deceptive?

• The material contains toxins or harmful components that would make the resulting compost unusable.
• It won’t compost safely or in a timely manner in a home compost pile.
• The claim misleads reasonable consumers about the environmental benefit.
• Failure to disclose that there are limited (or no) facilities available that can compost the material (especially certain types of plastics that may require special treatment in order to decompose properly.)

Qualified Claims

In certain circumstances, you can qualify your claim if necessary. For example, if the package contains bio-plastics, you could say that it’s not suitable for home composting and may need to include a statement that commercial composting facilities may not be available in all areas.

State Regulations

Some states have even more specific regulations addressing when you can claim your package is compostable.

For example, in Washington State, any products² claiming to be “compostable” that are sold, offered, or distributed in the state must meet the following requirements:

• Meet the US FTC guide for labeling requirements.
• Feature labeling that meets industry standards for being distinguishable.
• Display a logo of a recognized third-party verification.
• Clearly display the word “compostable.”
• Packaging must use green, beige, or brown labeling and color striping to help differentiate compostable products from non-compostable products.
• Submit a “product declaration” to Washington State Ecology for each compostable product.

If you sell online to customers in Washington, you may fall under these regulations.

California, Maryland, and Minnesota have similar laws on their books.

All these states also prohibit the use of the terms “biodegradable,” “degradable,” or “decomposable” on any plastic product.

What should you do?

Research carefully if you want to use environmentally friendly compostable materials for your packaging.

Get documentation from the supplier that covers not only the material itself but also any adhesives used. Verify that the documentation specifies what type of composting facility is necessary to compost the material adequately.

If you print onto the paper or labels, verify that the ink is non-toxic and will not adversely affect the usability of the resultant soil or mulch.

If you sell locally, determine if your area has appropriate composting facilities. If you sell nationwide, research the availability of the type of facility necessary to compost your packaging.

Formulate the “compostable” statement for your label based on all the information you have. Qualify it if necessary.

And, of course, keep records and documentation backing up what you say, proving that you are not being deceptive if you claim your product package is "compostable."