THE PROCESS IN MOTION

From the empty bag to the sorting bin: who answers for what, and when?

Start the scene or choose a stage. The animation simplifies the mechanism; what follows gives the details and the available references.

▶ Play the process01The empty bags02Filling03Printing04The parcel05The kitchen062028 and after

The empty bags

A pallet of valve bags arrives at the roastery with two papers: the written declaration of conformity for food contact, which the plastics regulation imposes on the supplier, and the supplier’s attestation on PFAS, those fluorinated compounds that make paper waterproof. The roaster files them in the technical file: packaging is bought with its proofs.

Read the stages without animation

1. The empty bagsA pallet of valve bags arrives at the roastery with two papers: the written declaration of conformity for food contact, which the plastics regulation imposes on the supplier, and the supplier’s attestation on PFAS, those fluorinated compounds that make paper waterproof. The roaster files them in the technical file: packaging is bought with its proofs.
2. FillingThe beans fall, the sealer closes the bag, the roastery logo appears. Whoever fills under their own brand becomes the “manufacturer” of the packaging within the meaning of the European regulation applicable since August 12, 2026: conformity assessment, technical documentation, signed EU declaration of conformity. A microenterprise served by a supplier in the same country leaves this role to the supplier.
3. PrintingOn the bag are printed the lot number, the name and the address, which the regulation requires of the manufacturer, then the Triman and the Info-tri, the French sorting signs. The word “biodegradable” tries to join in and fades away: French law has forbidden it on a product or packaging since January 1, 2022. What one writes is as regulated as what the bag contains.
4. The parcelThe bag leaves in a half-empty shipping carton: from 2030 at the earliest, the empty space of a parcel will not exceed 50%, paper shred and air cushions included. At year’s end, the roastery declares its packaging by material to its eco-organization, paper, plastic, aluminum: end of life is paid in advance, by weight and by material.
5. The kitchenIn the customer’s kitchen, the empty bag, the aluminum capsule and the paper pod arrive before the yellow bin and the biowaste bin. The bag and the capsule go in the yellow bin, where all packaging made of metal, plastic and cardboard goes; the paper pod goes to the compost. The sorting gesture depends on the material and the collection, not on the printed word.
6. 2028 and afterThe Triman dissolves and gives way to a European pictogram of materials, followed by a question mark. The harmonized label is due by August 12, 2028 at the latest, or twenty-four months after the implementing act that will design it; this act was expected on August 12, 2026 and has not appeared. National sorting labels will not be able to stay.

To remember: A roaster that bags under its own brand is the “manufacturer” of its packaging: technical file, EU declaration of conformity, lot and address on the bag, except for a microenterprise served by a supplier in the same country.

In history: In history: the anti-waste law of February 10, 2020 has forbidden the word “biodegradable” on packaging since January 1, 2022; the Conseil d’État upheld it on May 31, 2024.

Read the full article and its sources ↓

State of the law as of October 21, 2026. 7 deadlines fall after this date; they are listed at the end of the section.

Three tiers for a single bag

Contact falls under health regulations, waste under a Union regulation applicable since August 2026 and the Environment Code, claims under that same code and consumer law. A valve bag can therefore be irreproachable on contact, compliant on sorting, and illegal because of a single word printed on it.

Contact: yield nothing to the coffee

Regulation (EC) No 1935/2004 lays down the general rule: made according to good practice, a material does not transfer to food constituents that endanger health, change its composition or impair its organoleptic characteristics, that is, what the nose and mouth perceive (Article 3); a film that gives the bean a plastic taste is non-compliant even if harmless. It also requires the traceability of materials at all stages (Article 17, source 1). For plastics, Regulation (EU) No 10/2011, consolidated as of July 14, 2026, admits only substances on the “Union list” (Article 5) and has the material circulate, at all stages other than retail, with a written declaration of conformity from the supplier (Article 15, source 2). The roaster that buys bags, boxes or empty capsules must receive it and keep it. The degassing valve, a disc that lets the carbon dioxide out of fresh beans without letting air in, has no rule of its own that was found: it falls under the general contact regime and, on the waste side, under what the packaging regulation calls an “integrated component,” which is part of the packaging unit and is disposed of with it (Article 3 of Regulation 2025/40, source 4; attachment made by this pass).

The Union list explains a series of alerts. Of 107 notifications of the RASFF, the Union’s rapid alert system for food, whose title contains “coffee” between 2019 and 2026, 26 concern materials in contact with food, twelve of them cups loaded with bamboo powder and seven objects loaded with rice husk, straw or spent coffee grounds and coffee husks (source 9, query of October 21, 2026, classification made in this pass). The plant fiber is not judged dangerous there: it is not a substance authorized in a plastic.

Bisphenol A, known as BPA, a component of polycarbonates and of some varnishes of metal cans, is banned in contact with food by Regulation (EU) 2024/3190, in force since January 20, 2025, with a phase-out in stages: a single-use BPA packaging could be placed on the market until July 20, 2026 and filled within the following twelve months; certain packaging and professional equipment have until January 20, 2028; a reusable object, cup or machine part, may stay on sale until January 20, 2029 (Articles 11 and 12, source 3). French Law No. 2012-1442 had got ahead (source 10, effective date not reread).

The packaging regulation: who is the “manufacturer” when you roast

Regulation (EU) 2025/40 on packaging and packaging waste, which the Commission abbreviates REDE in French and the press PPWR (its English acronym), published on January 22, 2025, has applied since August 12, 2026 and repeals Directive 94/62/EC on that date (Articles 70 and 71, source 4). It applies directly, without a French law, and a Member State may not hinder packaging that complies with its Articles 5 to 12 in the name of national requirements (Article 4).

The “manufacturer” is whoever makes a package or a packaged product, but also whoever has it designed or made “under its own name or trademark” (Article 3, point 13). For sales packaging, the Commission specifies, this is in principle “the person who fills,” often the owner of the brand (guidance document of June 10, 2026, source 11). The roaster that bags under its own name is therefore the manufacturer of its bags, even if it buys them printed. Exception: if the brand owner is a microenterprise within the meaning of Recommendation 2003/361/EC (fewer than ten persons, with a ceiling on turnover or balance sheet) and its packaging supplier is established in the same Member State, it is that supplier who is the manufacturer (Article 3, point 13(b)). Article 15, paragraph 12, for its part, speaks of a supplier “located in the European Union” (see the gray areas).

Being a manufacturer entails four things (Article 15). Before placing on the market, carry out the conformity assessment of Annex VII, draw up the technical documentation and sign an “EU declaration of conformity” on the model of Annex VIII, by which the manufacturer “takes responsibility” for conformity (Article 39). Keep these documents five years for single-use packaging, ten years for reusable. Carry a lot number, the name or brand and a single postal address, on the packaging or by QR code. In case of non-conformity, correct, withdraw or recall, warn the authorities and hand them the documentation within ten days of a reasoned request. The supplier’s declaration under food contact does not replace this one: it becomes one of its documents.

Article by article: each coffee package

The regulation mentions coffee twice in its definition of packaging: “a permeable bag of tea, coffee or another beverage, or a single-use pod that is flexible after use,” and “a non-permeable single-use pod” intended for a machine (Article 3, point 1(f) and (g)); Annex I also places “tea and coffee bags in aluminum foil” among packaging (source 4).

The flexible pod, paper included, will have to be compostable by February 12, 2028 at the latest throughout the Union, the rule being, the Commission says, “neutral from the point of view of materials” (Article 9, paragraph 1, source 11). For the rigid capsule, a State that collects waste of comparable compostability together with biowaste may require it to be compostable, unless it is metal (Article 9, paragraph 2). Takeaway coffee has its dates: on February 12, 2027, the foodservice distributor (the text says horeca, for hotels, restaurants, cafés) offers to fill the customer’s container at no extra charge (Article 32); on February 12, 2028, it offers reusable packaging, unless it is a microenterprise (Article 33); on January 1, 2030, single-use plastic cups used on the premises and plastic portions of cream or sugar disappear from the dining room (Article 25 and Annex V, points 3 and 4).

PFAS, recyclability, recycled content, empty space

Since August 12, 2026, packaging in contact with food may no longer contain PFAS, the per- and polyfluoroalkyl substances that make a paper grease-resistant, above 25 ppb (parts per billion) for a PFAS measured by targeted analysis, 250 ppb for their sum and 50 ppm (parts per million) for the total, polymers included (Article 5, paragraph 5). The Commission adds that no sell-off period is provided, that there is no exception for recycled material, and that no harmonized analysis method yet exists (source 11). The supplier’s proof goes into the technical documentation (Article 5, paragraph 6).

All packaging will have to be recyclable and graded by its recyclability by weight per unit: class A from 95%, B from 80%, C from 70% (Annex II, table 3). From January 1, 2030, or twenty-four months after the delegated act that will set the criteria if that is later, packaging outside classes A to C may no longer be placed on the market; from 2035, the grade takes into account the recycling actually done “at scale”; on January 1, 2038, only A and B remain permitted (Article 6). The criteria must “apply to all packaging elements,” a valve or a closure for example (paragraph 4). The delegated act is expected by January 1, 2028 at the latest; until then, the manufacturer follows the old directive and the standard EN 13430 (source 11). The detailed grades for capsules are given in the page on capsules, in the waste plate.

In 2030 as well, every plastic part of a food package, called “contact-sensitive,” will contain 30% recycled plastic if it is PET (polyethylene terephthalate) and 10% for other plastics, then 50% and 25% in 2040; compostable plastics and any part under 5% of the unit’s mass are exempt (Article 7). The manufacturer will reduce weight and volume to the necessary minimum, and double walls, double bottoms and unnecessary layers will be banned, except for a shape protected before February 11, 2025 by a design, a model or a trademark, or produced under a geographical indication, which might cover a coffee under a protected indication (Article 10; reading of this pass, see section 10). Finally, the operator who fills a shipping carton or an online parcel will not exceed 50% empty space, crinkle fill and air cushions counting as empty space (Article 24, paragraphs 1 to 3). For the bag itself, empty space is reduced to the minimum from February 12, 2028, but the air between the beans and protective gases, the nitrogen of a nitrogen-flushed bag for example, do not count, and conformity is assessed at filling for a product that settles (paragraph 4).

The harmonized label, the Triman and the Info-tri

By August 12, 2028 at the latest, or twenty-four months after the implementing act that will define it, all packaging will carry a harmonized label of pictograms showing its materials; for a compostable pod, it will say that it is compostable, that it is not suitable for home composting and that it must not be dumped in the environment (Article 12, paragraph 1). The implementing act was due on August 12, 2026 (paragraph 6): a title search in the Publications Office database, on October 21, 2026, found none (source 19). The date may slip.

France imposes its own signage: Article L. 541-9-3 of the Environment Code requires the party placing on the market a household product subject to an extended producer responsibility (EPR, the principle that has the seller finance end of life) stream to indicate that the product is to be sorted and how (source 7), in the form of the Triman logo and the Info-tri block set by Decree No. 2021-835 of June 29, 2021 (source 8); under 10 cm² of main face, the information may go online. Failure is punished by an administrative fine capped at 15,000 euros for a company (Article L. 541-9-4). But the Commission judges European labeling “exhaustive and fully harmonized”: national rules that add sorting instructions are not allowed, and national labels may not be kept after August 12, 2028, or twenty-four months after the implementing act (source 11). The Triman is one of them. Earlier, on February 12, 2027, the sign of belonging to an extended responsibility stream may appear only in a QR code (Article 12, paragraph 9). No French decision on the Triman was found.

In France: the words no longer printed

Article L. 541-9-1 of the Environment Code, from Law No. 2020-105 of February 10, 2020, known as AGEC (anti-waste for a circular economy), has banned since January 1, 2022 the statements “biodegradable,” “environmentally friendly” or equivalents on a product or packaging; a plastic whose compostability “can be obtained only in an industrial facility” cannot be called “compostable,” and every compostable plastic carries “Do not litter” (source 5). The Conseil d’État validated the implementing decree on May 31, 2024: the ban targets statements too general to be verified, not certified labels (source 6). The fine goes up to 15,000 euros for a company (Article L. 541-9-4-1, source 7). The same law has banned since January 1, 2022 “tea and herbal tea bags in non-biodegradable plastic,” without naming coffee (Article 77, source 14): the permeable coffee bag falls only under the European rule of 2028. A contradiction remains: the plastic capsule compostable only in an industrial facility cannot be called “compostable” in France, whereas the European label will have to announce it that way, and Union law prevails.

Paying for end of life: extended producer responsibility

In France, the company that places packaged products intended for households on the market must provide for the management of their waste or contribute to it (Articles L. 541-10 and R. 543-56, recalled by an eco-organization, source 15). In practice, the roaster joins an approved eco-organization, Citeo being the best known, declares its packaging to it each year by material and pays it an eco-contribution calculated on this declaration, the amount of which is not dealt with here. Since January 1, 2022, it receives a unique identifier, known as the IDU, assigned by ADEME (the Environment and Energy Management Agency), which it must show in its general terms of sale or, failing that, in its contractual documents, website included; an online marketplace checks that its sellers have one (Article L. 541-10-13, source 15).

The European regulation harmonizes these practices. The “producer” is whoever first makes a packaged product available on a territory (Article 3, point 15); it registers in the register of each State where it sells and declares its quantities there each year by June 1, with a lighter declaration under ten tonnes (Article 44). The roaster that sells online to consumers in another Member State becomes a producer there, must register there and appoint an authorized representative there (Article 3, point 15(d), and Article 45, paragraph 3); platforms and logistics providers check its number before serving it. Contributions may be modulated according to the recyclability class and the share of recycled material (Articles 6 and 7), which France calls eco-modulation. For professional packaging, cartons delivered to cafés, bags of green, pallet film, the French stream was postponed to January 1, 2027 according to a professional federation, which names the approved eco-organizations Twiice, Citeo Pro and Léko Pro (July 31, 2026, source 18, text of the postponement not read).

Who controls, and what happens to non-compliant packaging

According to customs, on August 10, 2026, the competent authority is the Directorate-General for Risk Prevention, the DGPR, of the Ministry of Ecological Transition; the declaration of conformity and the technical documentation are kept available to the market surveillance authorities; customs is not one for this text, but it can suspend release, that is, the handing over of the goods, for the time of a check (source 13). ADEME keeps the register of producers (source 15); misleading statements also fall to the DGCCRF, the Directorate-General for Competition, Consumer Affairs and Fraud Control. The split of controls under the new regulation among these services was not found in a text.

The authorities “endeavor” to verify a share of the declarations of conformity each year (Article 39, paragraph 5). Packaging that presents a risk is assessed, corrected within a set time, then banned, withdrawn or recalled, and the other States are warned; if the risk passes to the food, it is the authorities for official food controls that are alerted (Article 58). A merely formal non-conformity is enough for withdrawal: missing declaration, incomplete documentation, silent QR code, missing manufacturer address; on substance, empty space, recyclability, recycled content, persistence triggers national penalties (Article 62), which each State must set by February 12, 2027 at the latest (Article 68); no French scale had been found as of October 21, 2026.

Capsules in detail

The rigid capsule for a machine is packaging “used and disposed of with the product” (Article 3, point 1(g)); the flexible pod after use, paper or not, falls under the mandatory compostability of 2028 (source 11).

Aluminum. Metal is excluded from the compostability option (Article 9, paragraph 2(a)): the capsule will always be judged on its recyclability. ADEME says to put the capsule “in aluminum or plastic” in the packaging sorting bin (source 16), and Citeo writes that all packaging in metal, plastic and cardboard goes into the yellow bin since January 1, 2023 in mainland France and since January 1, 2026 in the overseas territories (source 17); this is no doubt what the alliance of capsule manufacturers sums up as sorting “everywhere in France” since 2026 (source 12, link made by this pass). Actual recycling then depends on the sorting center, which must capture small metals; some brands also have bins in their shops (source 16).

Plastic. Same sorting instruction (sources 16 and 17). The capsule will have to reach a recyclability class and contain 10% recycled material in 2030, 25% in 2040, unless it is compostable (Article 7); no French decision requiring its compostability was found.

Compostable. The regulation distinguishes “compostable” packaging, which decomposes under controlled industrial conditions, anaerobic digestion included, “but not necessarily” in the garden, and “home compostable” packaging (Article 3). Pending harmonized standards, the standard EN 13432 on industrial composting serves as guidance, with no presumption of conformity (source 11). In France, the paper or cardboard capsule goes to biowaste or the composter, if there is one (sources 16 and 17); the plastic capsule compostable only in an industrial facility cannot be called “compostable” and bears “Do not litter.” Three materials, three actions, and a statement that one is not allowed to read in France on a capsule that will carry it elsewhere.

The sources for this section

1. Regulation (EC) No 1935/2004 of October 27, 2004, materials in contact with food, Articles 3, 15, 16 and 17 · online · primary
2. Regulation (EU) No 10/2011, plastic materials, consolidated version of July 14, 2026, Articles 5 and 15 · online · primary
3. Regulation (EU) 2024/3190 of December 19, 2024, bisphenol A and other bisphenols, OJ of December 31, 2024, Articles 2, 11, 12 and 14 · online · primary
4. Regulation (EU) 2025/40 of December 19, 2024, packaging and packaging waste, OJ of January 22, 2025, Articles 3 (points 1, 13 to 18 and definitions of composting), 4, 5, 6, 7, 9, 10, 12, 15, 24, 25, 29, 32, 33, 38, 39, 44, 45, 58, 62, 68, 70, 71, Annexes I, II (table 3) and V · online · primary · reading: yes (full text downloaded from the Publications Office)
5. Environment Code, Article L. 541-9-1, version in force since January 1, 2022 (Law No. 2020-105, Art. 13) · online · primary · reading: yes (Légifrance via WebFetch on October 21, 2026, cited paragraphs verified)
6. Conseil d’État, May 31, 2024, No. 464945, ECLI:FR:CECHR:2024:464945.20240531 · online · primary · reading: yes (Wayback capture of 2025, the site was returning 503)
7. Environment Code, Articles L. 541-9-3, L. 541-9-4 and L. 541-9-4-1, versions in force as of October 21, 2026 · online · primary · reading: summary (Légifrance via summarizer, previous pass)
8. Decree No. 2021-835 of June 29, 2021, consumer information on the sorting rule, Article 3 and Article R. 541-12-21 · online · primary · reading: summary (Légifrance via summarizer, previous pass)
9. RASFF Window, notifications whose subject contains “coffee,” query of the public API on October 21, 2026 (107 notifications, 26 of them “food contact materials”) · online · public data
10. Law No. 2012-1442 of December 24, 2012, suspension of food packaging containing bisphenol A · online · primary · reading: summary (title and date only)
11. Commission, guidance document on Regulation (EU) 2025/40, C/2026/3084, OJ C of June 10, 2026, points on the manufacturer, PFAS, recyclability, Article 9 and labeling (points 9 and 13) · online · primary · reading: yes (full text downloaded, cited passages verified)
12. Communication from a capsule manufacturer on yellow-bin sorting since January 1, 2026, on behalf of the ARCA alliance (interested source) · online · secondary · reading: summary (search engine, previous pass)
13. Directorate-General of Customs and Indirect Taxes, “Entrée en vigueur du nouveau règlement relatif aux emballages,” August 10, 2026 · online · primary · reading: yes (WebFetch on October 21, 2026)
14. Law No. 2020-105 of February 10, 2020, Article 77 (tea and herbal tea bags in non-biodegradable plastic, January 1, 2022) · online · primary · reading: yes (Légifrance via WebFetch on October 21, 2026)
15. Adelphe, sheet “Tout comprendre sur le nouvel identifiant unique ADEME de la REP emballages ménagers,” November 2021 (reminder of Articles L. 541-10, R. 543-56 and L. 541-10-13 by an eco-organization) · online · secondary · reading: yes (PDF extracted locally)
16. ADEME, “Que faire de mes déchets,” sheet “Capsules de café ou de thé” · online · primary · reading: yes (WebFetch on October 21, 2026, undated page)
17. Citeo, consumer pages “On ne lâche rien !” (extension of the sorting instructions on January 1, 2023, pods) and “Outre-mer” (extension on January 1, 2026) · online · secondary (eco-organization) · reading: yes (WebFetch on October 21, 2026; citeo.com was returning 502 and blocks robots)
18. French Building Federation, “REP Emballages professionnels : report confirmé au 1er janvier 2027,” July 31, 2026 · online · secondary · reading: yes (official text of the postponement not read)
19. Publications Office, SPARQL endpoint of the Cellar: acts whose French title cites Regulation 2025/40 since March 2025, and acts that take it as legal basis (corrigendum of May 22, 2025, Delegated Decision (EU) 2026/429 of February 25, 2026 on pallets and straps, guidance document) · online · public data · reading: yes (query of October 21, 2026)