POLICY & REGULATION · 20 min read
Ceylon Tea’s Next EU Deadline Is 12 February 2028 — and It Asks for a Different Bag, Not a Different Form
The EU’s packaging regulation applied on 12 August. Almost everything it demanded of a Sri Lankan supplier that day was documentary in nature. The obligation that reaches Ceylon tea hardest arrives eighteen months later, and it is not a document at all: from 12 February 2028, permeable tea bags placed on the EU market must be industrially compostable.
By the ESGNexus Editorial Team · August 2026 · Estimated reading time: 20 minutes
KEY TAKEAWAYS
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On 12 August 2026, Regulation (EU) 2025/40 — the Packaging and Packaging Waste Regulation — entered into force across the European Union. For a Sri Lankan exporter, the practical effect that day was narrow and, on the whole, administrative: a chemical limit on PFAS in food-contact packaging, a declaration of conformity drafted by the manufacturer, a producer registration that falls on the EU importer rather than on the supplier in Colombo. Documents, in other words, and mostly somebody else’s documents.
On 12 February 202,8 that changes. Article 9 of the same regulation does not ask for a form. It asks for a different bag.
What Article 9 Actually Says
Article 9 is the compostability provision. It names three packaging formats and requires each to be compostable under industrial conditions: sticky labels attached to fruit and vegetables; permeable tea, coffee, and other beverage bags; and soft single-serve units that are disposed of together with the product they contain. The European Commission’s Directorate-General for Environment sets out the second of those in its own guidance, and the wording leaves very little room:
| Permeable tea, coffee or other beverage bags… are mandatorily compostable. — European Commission, DG ENV, PPWR Frequently Asked Questions, March 2026 |
The full sentence covers “permeable tea, coffee or other beverage bags, or soft after-use system single-serve units that contain tea, coffee or another beverage, which are intended to be used and disposed of together with the product”. The date on which it starts to bite is given by the Commission in the same document, in the course of explaining what Member States must do with the resulting waste: because Article 9 applies from 12 February 2028, Member States are not required to accept compostable packaging in the bio-waste stream before that date, though they are encouraged to.
Source: European Commission, DG ENV Unit B01, ‘Packaging and Packaging Waste Regulation (PPWR) Frequently Asked Questions’, March 2026. The document is the Commission’s; the copy read for this article was hosted by a law firm because the Publications Office download handler and the EUR-Lex guidance route both refused automated access on 21 August 2026. The formats and the date are independently corroborated by European Bioplastics and, for the date, by the EU Delegation to Sri Lanka’s own publication of 18 August 2026.
The date reconciles against the regulation’s own arithmetic. PPWR entered into force on 11 February 2025 and applied eighteen months later, on 12 August 2026. Article 9 sits thirty-six months out, on 12 February 2028. Two of the three dates are already published Commission facts; the third follows the same day-after convention. It is worth noting the discrepancy because at least one industry source describing this provision places it at “approximately 34 months” after entry into force, which is incorrect even though the date is correct.
| Date | What happens |
| 11 February 2025 | Regulation (EU) 2025/40 enters into force. |
| 12 August 2026 | PPWR applies. For a non-EU supplier, the binding obligation is the PFAS limit for food-contact packaging; conformity documentation rests with the manufacturer, and EPR registration with the EU importer. |
| 12 February 2028 | Article 9 applies. Permeable tea, coffee and beverage bags, soft single-serve units disposed of with the product, and sticky labels on fruit and vegetables must be industrially compostable. Member States are not obliged to accept such packaging in bio-waste streams before this date. |
| From 12 February 2028 | Member States may add further formats to national lists of mandatorily compostable packaging, where collection schemes and treatment infrastructure exist. The obligation, therefore, is no longer uniform across the twenty-seven. |
| 1 January 2030 | Minimisation, empty-space ratios and format bans apply. |
Sources: European Commission Notice C(2026) 3702 final of 5 June 2026, published in the Official Journal on 10 June 2026 as C/2026/3084, for the 2025 and 2026 dates and the 2030 obligations; DG ENV PPWR FAQ, March 2026, for Article 9. Note that C(2026)3702’s forward-date list does not itself carry Article 9 — see ‘A correction to our own coverage’, below.
Why This One Is Different From Everything Else in PPWR
When ESGNexus examined PPWR in August, the conclusion was that the regulation reaches Sri Lanka commercially rather than legally: the enforceable duties fall on EU economic operators, and pressure reaches a Colombo exporter as a contract clause, a substantiation request, or a specification change, not as a customs seizure. That reading broadly holds, and Article 9 does not overturn it. But it needs one qualification that this newsroom did not make on 21 August: PPWR’s definition of a manufacturer carries no requirement that the person be established in the European Union, which is not obviously consistent with treating a Sri Lankan packer as wholly outside the regime. That question is taken up in the fifth of the exporter questions below.
What Article 9 changes is the character of the demand. A PFAS threshold can be met by switching a laminate and holding a test report. A declaration of conformity can be produced by an EU importer from information a supplier already has. A compostability requirement cannot be satisfied by any document. It requires a bag made of a different material, sourced from a different supplier, tested against a standard, and — because the tea inside it must still survive the shelf — requalified for barrier performance, seal integrity, and taste. That is a product development cycle, and product development cycles are measured in quarters.
The window between 12 August 2026 and 12 February 2028 sounds generous. Set against buyer specification cycles, packaging supplier qualification, shelf-life trials and the printing and tooling changes that follow, it is not obviously generous at all. The exporters most exposed are those who will hear about this from a European buyer in the form of a revised specification with an attached compliance date, rather than from a regulator.
What ‘Industrially Compostable’ Will Require — and Why That Is Not Yet Settled
The reference point is EN 13432, the European standard for packaging recoverable through composting and biodegradation. The Commission’s guidance treats it as the operative benchmark while stopping short of writing it into the regulation: the regulation does not explicitly require composting facilities to operate to the harmonised standard, the Commission says, but it expects that they will.
There is a complication behind that benchmark, and it is sharper than the guidance’s hedging suggests. EN 13432 is cited in the Official Journal as a harmonised standard under the 1994 Packaging Directive — the instrument PPWR replaces. The Commission’s guidance states that the standard “can be used as guidance until the new standard is adopted”, but that the presumption of conformity “will only be possible again from the date when a new decision listing relevant harmonised standards … is published in the Official Journal of the EU”. Again is the operative word. For now, an EN 13432 certificate is evidence a manufacturer can use, not a legal presumption they can rely on.
There is a second, more important caveat, and it runs in the exporter’s favour only if it is used. The Commission has said that associations representing industrial composting will be fully involved in developing the updated industrial compostability standards. The standard against which a 2028 tea bag will be judged is therefore still moving. A supplier who qualifies a material against today’s version and then stops paying attention may find in 2027 that the target has shifted. The correct posture is to start now and to keep a watch on the standard, not to buy a certificate and file it.
Two boundaries are worth stating precisely, because overstatement is the standing failure mode in compliance coverage of EU rules. First, non-permeable single-serve units designed for machine use are not mandatorily compostable under EU law; individual Member States may impose it where the infrastructure exists, but the regulation does not. Second, Article 9 is a formatting requirement that takes effect on a future date. There is no current ban on tea bags, and nothing in it prevents Ceylon tea from being sold in the European Union today.
A Correction to Our Own Coverage
On 6 August, ESGNexus published an analysis of PPWR that included a forward-date list — 2027, 2028, 2029, 2030 — drawn directly from the European Commission’s guidance notice C(2026)3702. That list does not contain Article 9. At the time, the only secondary source offering a compostables date gave 1 January 2028, and because it could not be confirmed against a Commission document, it was deliberately dropped rather than printed unverified.
The decision to drop an unconfirmable date was the right one. The consequence was that our readers did not get the deadline. The correct date is 12 February 2028; it comes from the Commission’s own FAQ, and it is now on this page. The lesson is narrow and worth carrying: a European Commission guidance notice and a European Commission FAQ are different documents from the same Directorate, and neither one’s list of dates should be treated as exhaustive.
The EU Said This in Colombo. The Version That Travelled Furthest Left the Date Out
On 18 August 2026 the Delegation of the European Union to Sri Lanka published a readout of a seminar held in Colombo on 13 and 14 July, run under the EU-funded CIRCULAR project — implemented jointly by Expertise France, the Food and Agriculture Organization and GIZ — which it says equipped more than 100 representatives of Sri Lankan businesses, packaging manufacturers, government institutions, industry associations and certification bodies to deal with the new packaging rules.
The release itself names both deadlines that matter: the ban on PFAS in food-contact packaging from August 2026 and the requirement for tea bags and selected packaging formats to be industrially compostable from February 2028. This was not hidden. It was published in English in Colombo by the European Union, and three people were quoted by name in it.
| As the Packaging and Packaging Waste Regulation comes into force, early preparation will be essential to help businesses adapt smoothly, maintain access to the EU market, and strengthen their position in an increasingly sustainability-driven global economy. — Dr Johann Hesse, Head of Cooperation, Delegation of the European Union to Sri Lanka, 18 August 2026 |
Mahmoud Gaballah, Project Manager of the CIRCULAR Project at Expertise France, put the commercial case more bluntly: “The transition to sustainable packaging is no longer simply an environmental aspiration; it is becoming a business imperative.” Nishan Perera, President of the Sri Lanka Institute of Packaging, added the domestic view: “For Sri Lanka’s export-driven food and packaging sectors, understanding these complex EU regulations is very important.”
The local pickup was uneven, and it is worth being precise about how it was uneven. At least two outlets carried the February 2028 line on the day it was published: Sri Lanka Chronicle and Jaffna Monitor, which rendered it as “a requirement that tea bags and certain other packaging formats be industrially compostable from February 2028”. The date was therefore available to a Sri Lankan reader on 18 August. What did not survive was the version that traveled the farthest. Two days later, on 20 August, the widely syndicated wire copy described PPWR instead as requiring that all packaging placed on the EU market be recyclable by 2030, listed apparel, tea, spices and processed food as the exposed sectors, and named neither Article 9 nor the compostability date.
The distinction matters more than a scorecard of which outlet printed what. A reader who saw the fuller coverage came away with a specific obligation attached to a named product and a fixed date. A reader who saw only the syndicated version came away with a general 2030 anxiety. The general anxiety cannot be acted on. The specific obligation can — and the gap between the two is not a failure of publication but of circulation.
How Much Is at Stake — and What We Will Not Claim
Tea earned Sri Lanka US$1,507.19 million in export revenue in 2025, on the Export Development Board’s figures. The European Union took 24% of the country’s merchandise exports in the same year, worth roughly US$3,261 million, up 13.41%.
Those are two separate facts, and this article will not multiply them together. Doing so would assume that tea’s European share matches the all-goods European share, and no source we could find establishes that. Nor could we find a figure for the proportion of Ceylon tea reaching EU consumers in permeable bag format rather than as loose leaf or in non-permeable formats. That number is the one that would size this obligation exactly. It is not published — but it does exist in a government database, and the fourth of the exporter questions below says exactly where.
What Sri Lankan Tea Exporters Are Asking
Five questions come back from exporters whenever this obligation is presented to them. Each is answered below, drawing on the European Commission’s own guidance document on Regulation (EU) 2025/40, read in full text this week, the certification bodies that actually issue EN 13432 certificates, and Sri Lanka’s own published trade statistics. Where those sources do not answer, the answer says so rather than filling the space.
Two of the five answers correct the premise of the question. That is not evasion. It is where the useful information is.
1. What materials and suppliers actually meet EN 13432 for a permeable tea bag?
Start with what the standard measures, because the answer to the question follows mechanically from it. EN 13432 is a pass-or-fail scheme with four tests, and a packaging item has to pass all four.
| Test | The threshold | What it means for a tea bag |
| Biodegradation | At least 90% of the carbon is converted to carbon dioxide within a maximum of six months, in compost at 58 ± 2 °C. | Measures the material itself. A fossil polymer does not reach 90% in six months, at any inclusion level. |
| Disintegration | After twelve weeks, no more than 10% of the original dry weight may remain as fragments larger than 2 mm. Tested to ISO 16929 or ISO 20200. | Measures the finished item. A mesh that holds its shape because a synthetic fiber is holding it together fails here. |
| Heavy metals and fluorine | Eleven regulated elements with ceilings in mg per kg of dry sample: arsenic 5, cadmium 0.5, chromium 50, copper 50, fluorine 100, mercury 0.5, molybdenum 1, nickel 25, lead 50, selenium 0.75, zinc 150. | Reaches inks, dyes and pigments — including anything printed on a tag. |
| Ecotoxicity | Plant germination and biomass at least 90% of a control, on a minimum of 100 seeds, using OECD 208 as modified by EN 13432 Annex E. | Measures what the resulting compost does to a growing plant. |
Now the clause that decides the answer. Compostability attaches to the item, not to its main material. Eurofins, the accredited laboratory group, puts it plainly: packaging “may be deemed to be compostable only if all the constituents and components of the packaging are compostable”. TÜV AUSTRIA, which issues the OK compost INDUSTRIAL mark, says the requirement “applies to all components, inks and additives”. The British Plastics Federation adds that it is “the final combination / product, not just its constituent parts” that must pass every test.
This locates the problem precisely, and it is not the paper. It is the seal. A heat-sealed tea bag is sealed because the filter paper carries a thermoplastic fiber that melts under the sealing jaw. The UK Tea & Infusions Association states that this fiber was “typically made of polypropylene (PP) or nylon, but increasingly, polylactic acid (PLA) is used”. A 1991 patent for heat-sealable tea bag paper describes the conventional construction as “about 75% of natural fibers and about 25% of heat-sealing synthetic materials”—old and quoted for the principle rather than as a current market figure, but the principle has not changed.
The same association notes that “typically about 1% of a tea bag’s total weight is plastic (around 0.04g) – 95% is tea”. That figure is widely repeated as reassurance, and it does not survive contact with this regulation, for a reason worth stating carefully: the 1% has the tea in the denominator. EN 13432 and Article 9 apply to the packaging, not to the packaged product. Measured against the filter paper alone — which is the packaging item — the synthetic fraction is an order of magnitude larger. That reading is ours; no source states it in those terms, and it is offered as reasoning rather than as a quotation.
One further defense is already closed. The Commission’s guidance addresses head-on the argument that a paper bag falls outside the provision:
| Article 9(1) is a material-neutral provision and could refer to permeable tea, coffee or other beverage bags, or soft after-use system single-serve units made of any material, including paper-based single-serve units. Therefore, pursuant to Article 9, such packaging must be designed to be compostable by 12 February 2028. — European Commission, Commission Notice C(2026) 3702 final, 5 June 2026 |
So, a paper bag is in scope, and a paper bag sealed with polypropylene or polyester fiber is the format most likely to fail. The materials being qualified against the standard are PLA mesh, abaca, and wood-cellulose filter papers using a PLA heat-sealing fiber, as well as non-heat-sealable constructions that are folded and stapled or stitched instead of sealed. Named products exist in each family, and their manufacturers publish compostability claims for them. This article does not verify any of those claims, and neither should a buyer. We could not query either European certification register — both TÜV AUSTRIA’s and DIN CERTCO’s are live search applications that would not return results to us — so every product-level claim we found remains a seller’s claim.
One data point does more work than any marketing sheet. When Ahlstrom, one of the largest tea filter media manufacturers, announced TÜV AUSTRIA compostability certification for its tea filter portfolio in July 2023, the certification covered its non-heat-sealable range, and the release described an ambition to extend it to heat-sealable grades. The seal is the hard part, and the industry’s own certification record says so.
Sources: TÜV AUSTRIA Belgium, OK compost INDUSTRIAL scheme documents ID-411 and ID-415 (rev. 2407, 24 July 2024) — okcert.tuvaustria.com; British Plastics Federation, ‘Standards for compostability’ — bpf.co.uk; Eurofins, ‘Biodegradable and compostable packaging’, issue 21 July 2021 — eurofins.com. Heavy metal ceilings and the biodegradation and disintegration thresholds are given identically by two independent sources. Method note: EN 13432 is a paywalled standard, and we have not read its clause text; each criterion above is a restatement by a certification body, an accredited laboratory, or a trade association. Heat-seal composition: UK Tea & Infusions Association, tea.co.uk; US Patent 5,173,154 (Unicon Papier und Kunststoffhandel GmbH, published 22 December 1992). Ahlstrom press release, 6 July 2023 — ahlstrom.com.
2. How will exporters be notified when the updated standard is finalized?
Nobody is going to write to you. There is no notification list, no registry of affected third-country suppliers, and no channel through which the European Commission communicates with a tea packer in Ratnapura. But the question has a more consequential answer than that, and it is one almost nobody in this market has registered.
The presumption of conformity for compostable packaging is not currently available. The Commission’s guidance document says so in these terms:
| The existing standard EN 13432 on industrial composting can be used as guidance until the new standard is adopted. However, the presumption of conformity with the new harmonised standards on compostable packaging will only be possible again from the date when a new decision listing relevant harmonised standards, as requested by the Commission pursuant to Article 9(6), is published in the Official Journal of the EU. — European Commission, Commission Notice C(2026) 3702 final, 5 June 2026 |
Read that carefully, because it changes what a certificate is worth. EN 13432 was cited in the Official Journal as a harmonised standard under the 1994 Packaging Directive — the citation dates to February 2005 — and that Directive is the instrument PPWR replaces. Until a fresh Commission decision lists harmonised standards under the new Regulation, an EN 13432 certificate is evidence of compliance, not a legal presumption of it. The Commission says the same thing about national schemes: existing certifications “may be used by manufacturers to demonstrate compliance with Article 9, but such certifications do not create a presumption of conformity”.
That is not a reason to stop certifying. It is a reason to keep the qualification file open rather than treat a certificate as a closed matter — and it is the precise answer to the question, because the notification channel is the Official Journal of the European Union. The legally operative event is the publication of that listing decision. It is public, free, and searchable, and it is the only announcement that will actually change anything.
The timetable behind it should worry anyone planning for 2028. The guidance states that “by 12 February 2026, the Commission will request the European standardisation bodies to create a new, EU-wide standard” under Article 9(6). The guidance is dated 5 June 2026 and still describes that request in the future tense, against a deadline four months past. We could find no published decision containing the request, and no draft, work item or project reference for a revised EN 13432 at CEN — where the work sits with technical committee CEN/TC 261, subcommittee SC 4, on degradability and organic recycling of packaging.
The precedent is the arithmetic to hold on to. The last time the Commission asked CEN for a compostability standard, the mandate went out in 2016; CEN narrowed its scope; and the resulting standard, EN 17427 on home-compostable carrier bags, was published in July 2022. Six years. Set that against a compliance date of 12 February 2028 and a standardisation request that may not yet have been sent, and the realistic planning assumption is that the specification will still be moving when the obligation lands. European Bioplastics has described EN 13432 as “currently being revised” since July 2022, and no further progress has been found.
Three channels, then, in order of authority: the Official Journal, for the listing decision that restores the presumption of conformity; your certification body — TÜV AUSTRIA Belgium or DIN CERTCO, the two bodies that licence the Seedling mark in Europe — which has a commercial interest in telling certificate holders when the scheme changes; and your European buyer, who will hear it from their own compliance counsel and will pass it on as a revised specification. Only the first is authoritative. Only the third arrives with a date attached.
Sources: European Commission, Commission Notice C(2026) 3702 final, ‘Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste’, Brussels, 5 June 2026, published in the Official Journal on 10 June 2026 as C/2026/3084 — eur-lex.europa.eu, read in full text. European Commission, harmonised standards for packaging and packaging waste — single-market-economy.ec.europa.eu; Commission Decision 2001/524/EC, OJ L 190, 12 July 2001, and the EN 13432 citation at OJ C 44, 19 February 2005. European Bioplastics on the revision of EN 13432 (July 2022) and on the 2016 home-composting mandate (28 September 2016) — european-bioplastics.org. Note: the Commission’s harmonised standards page for packaging still refers only to Directive 94/62/EC and does not mention Regulation (EU) 2025/40. The CEN committee assignment is read from a standards catalogue listing rather than from CEN’s own register, which did not render; no work item number for a revised EN 13432 could be found.
3. Will a compostable bag shorten shelf life — and what protects it?
This question almost always contains a wrong assumption, and correcting it saves an exporter a great deal of misdirected work. A permeable tea bag is not a barrier and never was. It is porous by design and by legal definition — that porosity is what Article 9 uses to identify the format. It contributes nothing essentially to moisture or oxygen protection. What protects shelf life is the outer envelope or overwrap, and the carton or pouch beyond it.
Those outer layers are not named in Article 9. The provision reaches the permeable bag and the soft single-serve unit disposed of with the product. An individually wrapped sachet that a consumer tears open and discards separately is a different item under a different part of the Regulation. So the shelf-life question and the Article 9 question are, to a first approximation, about two different pieces of packaging — and an exporter who reformulates the outer wrap in response to Article 9 has solved a problem they did not have while leaving the one they do have untouched.
What genuinely changes when the inner bag changes is that it is narrower and more practical. The seal chemistry is different: replacing a polypropylene or polyethylene heat-sealing fiber with PLA changes sealing temperature, dwell time, and jaw pressure on an existing bagging machine, and seal integrity is what fails in transit. Wet strength at brewing temperature is a different property from dry strength on a production line. And taste and odor neutrality has to be demonstrated on your own tea, because it is an interaction between a substrate and a specific product, not a property of the substrate alone.
There is a fourth consideration particular to this country that no European supplier will raise. Compostable substrates are, by construction, materials engineered to break down in warm, humid, biologically active conditions. Warehousing and the pre-shipment leg are warm and humid. Storage stability before the product ever reaches a European shelf is a question worth putting to a supplier explicitly, with your own ambient conditions stated, rather than accepting a specification validated in a temperate climate.
We could find no published shelf-life or sensory study covering Ceylon tea in compostable filter media, and we are not going to invent best practice in its absence. The defensible position is the unglamorous one: run the trials on your own tea, in your own climate, on your own line, and test at the end of the intended shelf life rather than the start. An exporter who has those results in hand in 2027 is negotiating from a position of evidence. One who does not is accepting whatever specification the buyer’s packaging technologist writes.
The characterisation of permeable bags as non-barrier follows from the format definition used in Regulation (EU) 2025/40, Article 3(1), point (f), and from the Commission’s guidance on Article 9. The heat-seal substitution of PLA for polypropylene or polyethylene is documented by the UK Tea & Infusions Association and by filter-media manufacturers. The remaining process, storage, and sensory considerations in this answer are ESGNexus analyses, not findings drawn from a published study, and are labeled as such because no such study covering Ceylon tea could be located.
4. How much Ceylon tea reaches the EU in permeable bag format?
This is the number that would size the obligation exactly. It is not published, and this article said so on 21 August. What has changed is that we can now say precisely how large the exposed category is nationally, where the specific figure sits, and who holds it.
Start with the national picture, which is firm. According to the Tea Exporters Association’s published figures, Sri Lanka shipped 257,440 tonnes of tea in 2025, split by form as follows.
| Form | 2025 (tonnes) | Share of exports | In scope of Article 9? |
| Packeted tea | 116,245 | 45.2% | Only where the packet contains permeable bags. Loose leaf in a carton is untouched. |
| Bulk tea | 106,801 | 41.5% | No. Shipped for blending and packing in the destination market. |
| Tea bags | 26,444 | 10.3% | Yes — this is the exposed category. |
| Green tea | 4,922 | 1.9% | Only where sold in permeable bags. |
| Instant tea | 3,026 | 1.2% | No. |
Tea bags have accounted for almost exactly 10% of Sri Lanka’s tea exports by volume for three consecutive years — 10.4% in 2024, 10.3% in 2025, and 10.1% in the first half of 2026. That stability is itself useful: this is not a category in flux, and the exposure can be planned against.
Now the trap, because it is the one this file is most likely to produce. Sri Lanka’s value-added tea share reached 59% of exports in 2025, an 11-year high, and that figure is frequently cited. It is not a proxy for tea bags. Value-added is everything that is not bulk, and within it, packeted tea accounts for roughly 77%, while tea bags account for roughly 18%. Reading the 59% as a measure of tea-bag exposure overstates it by about 5.5 times. The shares are our arithmetic on the Association’s published tonnages, and the working is given so it can be checked.
The EU-specific figure is where the evidence stops. European customs data records imports from Sri Lanka under HS 0902.30 — black tea in immediate packings of 3 kg or less — totaling 10.89 million kg and about US$89.6 million in 2024, with Germany, Poland and the Netherlands together accounting for 84% of the total. That heading cannot answer the question, and it is important to say why rather than to quietly use it: HS 0902.30 merges packeted tea and tea bags into a single line, and since Sri Lanka’s packets outweigh its tea bags by more than four to one, any figure under that heading is dominated by packets. It is not a tea-bag number and must not be presented as one. Nor can the 10.3% national share be multiplied by an EU share, because that would assume the EU takes tea bags in the same proportion as the world average, and the available evidence suggests it does not.
That evidence is directional rather than quantitative, and it points in the same direction. The Tea Board’s own Sweden market study records that “Sri Lanka has many exporters that specialise in private-label services (string-and-tag, sachet and biodegradable pyramid bags, etc.), offering end-to-end products for retailers”, with Sri Lanka the second-largest supplier of black tea to that market at 15% by value. Unit values tell a consistent story: Ceylon tea entering the EU under the small-packings heading averaged about US$8.23 per kg in 2024, against a national average export price of US$5.85. That is the price signature of retail-ready product packed in Sri Lanka, not of commodity tea.
Here is the part worth acting on. The number exists. Sri Lanka Customs codes tea bags as a separate export line by destination — the Tea Board’s own newsletter of May to July 2026 prints a Jordan market table, sourced from Sri Lanka Customs, that separates Bags from Bulk and from three different packet sizes, and gives the bag figure for 2023, 2024 and 2025 individually. The coding is in place. The Tea Board publishes these tables one market at a time, and the available editions profile Jordan, Norway, the United States, and Canada. No EU market has been profiled. A single query to the Tea Board’s Statistical Division would produce the figure this article is missing, and ESGNexus will publish it.
Sources: Tea Exporters Association of Sri Lanka, export statistics by form, series through June 2026 — teasrilanka.org. Corroborated for 2025 by Daily FT reporting Forbes & Walker Research and Asia Siyaka. Shares of total exports and of the value-added category are our division of the Association’s published tonnages; the Association publishes tonnages, not shares. Value-added share of 59% for 2025, as reported by the Daily FT; it reconciles to 58.5% against the tonnages. HS 0902.30 figures for 2024 from WITS / UN Comtrade, EU-reported mirror data. Sri Lanka Tea Board Newsletter, May–July 2026 (Jordan market table, source Sri Lanka Customs) and the Sweden market study at Annexure I to the January–April 2026 newsletter — srilankateaboard.lk. The Sri Lanka Tea Board’s own statistics portal is a live database application and its 2024 annual report is a non-searchable scan; neither could be read directly, and the Association’s series is used in their place.
5. What documentation will EU buyers expect to prove Article 9 compliance?
The paperwork under PPWR is not a certificate. It is an EU declaration of conformity, and the Commission’s guidance is specific about who produces it: “The EU declaration of conformity (Article 39) must be drafted by the manufacturer, based on the information and documentation provided by suppliers pursuant to Article 16(1), or by an authorised representative, appointed by the manufacturer by a written mandate pursuant to Article 17.” Behind it sits a conformity assessment under Article 38, which “can be carried out by the manufacturer or by someone else on their behalf (e.g. a laboratory or a certification scheme)”, and technical documentation to Annex VII.
This raises a question this newsroom got too simple on 21 August, and we correct it here. We wrote that a Sri Lankan packer is not the regulated entity. That is not clearly right. PPWR defines a manufacturer as “any natural or legal person who manufactures packaging or a packaged product or has the packaging or packaged product designed or manufactured under its own name or trademark” — with no requirement that the person be established in the European Union, in pointed contrast to the definition of an importer, which is expressly a person “established within the Union”. The Commission adds that the manufacturer “is the sole economic operator bearing legal responsibility for the packaging’s compliance”, and tells a non-EU manufacturer holding only an EU branch to incorporate a subsidiary or appoint an authorised representative.
On the face of those definitions, a Sri Lankan exporter packing own-brand tea into permeable bags is a manufacturer of a packaged product. Whether that makes the obligation directly enforceable against a company in Colombo is a different question, and the honest answer is that enforcement is effected through the EU importer, who is the party a market surveillance authority can actually act against. We have not read Article 3(1) verbatim out of the Official Journal — see the source note — and this is a question for the buyer’s counsel rather than for a newsroom. But an exporter who assumes the entire file is somebody else’s is assuming something the text does not say.
In practice, what arrives is a buyer’s evidence request, and it is answerable. Four things are worth assembling before they are asked for.
| What to hold | Where it comes from | Why the buyer needs it |
| The packaging manufacturer’s declaration of conformity for the filter medium | Your filter paper or mesh supplier, under Article 39 | It is the document the Regulation actually names. A datasheet is not one. |
| The certificate number, the name of the certificate holder, and the issuing body | TÜV AUSTRIA Belgium or DIN CERTCO — the two bodies licensing the Seedling mark in Europe | Both maintain public registers. A number that can be looked up is worth more to a compliance officer than any claim that cannot be looked up. |
| A component list for the finished bag: mesh or paper, heat-seal fiber, thread, tag, staple, ink | Your own specification and your supplier’s | Compostability applies to the whole item. The buyer’s question will eventually reach the tag and the staple, and the Commission’s guidance does not yet say whether they are in scope. |
| Your own seal, brewing, and shelf-life trial results on the substituted material | Your production line and your QA | It is the only evidence in the pack that is yours, and it is the one that decides whether a 2027 specification change is negotiated or imposed. |
One warning, because it will otherwise cost somebody a shipment. An “OK Biobased” star rating is not a compostability certificate. It measures bio-based carbon content, an entirely different property, and it appears on tea filter media marketing with some frequency. A phrase such as “complies with EN 13432” on a datasheet is likewise a claim of conformity, not a certificate; the certificate has a number, a holder and an issuing body, and those three things can be checked in a register in about a minute.
Finally, a second documentary obligation is already on the calendar and is separate from Article 9. Under Article 12, packaging placed on the EU market must carry a harmonised label showing its material composition from 12 August 2028, or twenty-four months after the relevant implementing acts enter into force, whichever is later. Those implementing acts do not yet exist. An exporter reworking artwork for a compostable bag in 2027 should expect to rework it again for the composition label, and it would be sensible to plan one artwork cycle rather than two.
Source: European Commission, Commission Notice C(2026) 3702 final, 5 June 2026, published as OJ C/2026/3084 on 10 June 2026 — quoted verbatim on Articles 38, 39, 12, 15(2), 16(1) and 17 and on the obligations of non-EU manufacturers. The Article 3(1) definitions of ‘manufacturer’ (point 13) and ‘importer’ (point 17) are quoted from the ARA PPWR implementation guide and a published PPWR glossary, which agree; we have not read Article 3 verbatim on EUR-Lex, and the reading of what the manufacturer definition implies for a Sri Lankan exporter is ours and is offered as a question rather than a conclusion. Certification bodies and the Seedling license as set out in European Bioplastics, ‘Guidelines for the use of the Seedling logo’, July 2023 — dincertco.de.
What to Do Now
1. Audit which EU-bound SKUs use a permeable bag. One morning. Article 9 is format-specific, not product-specific. Loose leaf in a carton is untouched; a pyramid or heat-sealed bag inside that carton is not. Tea bags account for 10.3% of Sri Lanka’s tea exports by volume — the exposed category is real, bounded, and known.
2. Ask your filter media supplier three things, in writing: certificate number, certificate holder, issuing body. Not whether a compostable option exists. Every supplier will say it does. Those three items can be checked in the TÜV AUSTRIA or DIN CERTCO register in about a minute; a datasheet and a logo cannot.
3. Get the seal, not the paper, onto the agenda. The heat-sealing fiber is where a conventional paper bag fails EN 13432, and changing it affects the sealing temperature, dwell time, and pressure on your existing line. This is a machine qualification, not a purchasing decision.
4. Run your own shelf-life and sensory trials, in your own climate. No published study covers Ceylon tea in compostable filter media. Whoever holds trial results in 2027 negotiates the specification. Whoever does not accepts it.
5. Put one person on the Official Journal, quarterly. The date is fixed at 12 February 2028. The standard behind it is not: the Commission’s request to the European standardisation bodies was due in February 2026 and its June 2026 guidance still describes it in the future tense. The last comparable mandate took six years to produce a published standard.
None of this is a crisis. It is a lead-time problem, the more manageable kind and the one most often missed, because it produces no headline on the day it becomes unavoidable. The European Union has published the date. It has published it in Colombo. What an exporter does between now and 12 February 2028 is the only variable still open.
Sources & Further Reading
European Commission, DG ENV Unit B01, “Packaging and Packaging Waste Regulation (PPWR) Frequently Asked Questions”, March 2026 — europa.eu (copy read via khlaw.com; see source note)
Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste, OJ 22 January 2025 — eur-lex.europa.eu
European Commission, Commission Notice C(2026) 3702 final, “Guidance document for Regulation (EU) 2025/40 on packaging and packaging waste”, Brussels, 5 June 2026, published as OJ C/2026/3084 on 10 June 2026 — eur-lex.europa.eu
Delegation of the European Union to Sri Lanka, “European Union-Funded CIRCULAR Project Strengthens Sri Lanka’s Readiness for the EU Packaging and Packaging Waste Regulation (PPWR)”, 18 August 2026 — eeas.europa.eu
European Bioplastics, “Article 9 PPWR — Why certain packaging formats should be compostable”, 2026 — european-bioplastics.org
Sri Lanka Chronicle, “Seminar on EU Packaging Regulations Empowers Food Exporters in Sri Lanka”, 18 August 2026 — srilankachronicle.com
Jaffna Monitor, “New E.U. Packaging Rules Now Apply to Sri Lankan Exports”, 18 August 2026 — jaffnamonitor.com
Lanka Newspapers, “Sri Lankan Exporters Face Urgent Call to Comply With New EU Packaging Rules”, 20 August 2026 — lankanewspapers.com
Sri Lanka Export Development Board, “Sri Lanka’s export performance exceeded US$ 17.2 billion in 2025”, 2026 — srilankabusiness.com
TÜV AUSTRIA Belgium, “OK compost INDUSTRIAL” scheme, and comparison-of-standards documents ID-411 and ID-415 (rev. 2407, 24 July 2024) — okcert.tuvaustria.com
DIN CERTCO, “Industrially compostable products” certification scheme, and European Bioplastics, “Guidelines for the use of the Seedling logo”, July 2023 — dincertco.de
Eurofins, “Biodegradable and compostable packaging”, issue 21 July 2021 — eurofins.com
British Plastics Federation, “Standards for compostability” — bpf.co.uk
European Commission, harmonised standards under Directive 94/62/EC on packaging and packaging waste, and Commission Decision 2001/524/EC (OJ L 190, 12 July 2001) — single-market-economy.ec.europa.eu and eur-lex.europa.eu
European Bioplastics, “New EU standard and requirements for home compostable carrier bags” (July 2022) and “Revised mandate for home composting standard” (28 September 2016) — european-bioplastics.org
UK Tea & Infusions Association, “Tea FAQs” — tea.co.uk
US Patent 5,173,154, “Heat sealable tea bag paper and process of producing same”, published 22 December 1992
Ahlstrom, “Ahlstrom’s non-heat-sealable tea filter product portfolio receives home compostability certification”, 6 July 2023 — ahlstrom.com
Tea Exporters Association of Sri Lanka, export statistics by form, series through June 2026 — teasrilanka.org
Daily FT, “Tea exports top $1.5 b in 2025 despite price pressures”, reporting Forbes & Walker Research and Asia Siyaka — ft.lk
Sri Lanka Tea Board, Newsletter May–July 2026 (Jordan market table, source Sri Lanka Customs) and Annexure I to the January–April 2026 newsletter (Sweden market study) — srilankateaboard.lk
World Integrated Trade Solution / UN Comtrade, EU imports from Sri Lanka under HS 090230, 2024 — wits.worldbank.org
ARA, “Information on the Packaging and Packaging Waste Regulation (PPWR)”, implementation guide, for the Article 3(1) definitions — ara.at
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Data disclaimer: Information in this article is sourced from publicly available documents. ESGNexus does not independently verify company disclosures. Errors and omissions excepted.