What Certifications Are Required for Biodegradable Chinese Take out Boxes in the United States?
author: Iris
2025-12-17
1. Basis for Compliance of Biodegradable Chinese Take-out Boxes in the United States
1.1 FDA Regulatory Framework for Food Contact Materials
The U.S. Food and Drug Administration (FDA) regulates all materials that come into contact with food, including biodegradable Chinese take-out boxes. According to Section 409 of the Federal Food, Drug, and Cosmetic Act (FD&C Act), the FDA considers components in food contact materials that may migrate into food as "indirect food additives," requiring them to comply with the "no migration risk" principle. This means that the material must not release harmful substances under normal use conditions, and the migration amount must be below the toxicological safety threshold.
The FDA's regulatory system is based on the following regulatory hierarchy:
The FDA's regulatory system is based on the following regulatory hierarchy:
Core Law: FD&C Act (enacted in 1958), authorizing the FDA to develop specific rules
Implementing Regulations: 21 CFR Parts 170-199, which subdivide material categories and specify testing requirements
Compliance Guidelines: Such as the Compliance Policy Guides (CPG 7117 series), supplementing detailed testing requirements for special materials
Implementing Regulations: 21 CFR Parts 170-199, which subdivide material categories and specify testing requirements
Compliance Guidelines: Such as the Compliance Policy Guides (CPG 7117 series), supplementing detailed testing requirements for special materials
The FDA divides food contact materials into 17 major categories and has special requirements for biodegradable materials. Plastic products (21 CFR 177) must pass total migration (OML ≤ 10 mg/dm²) and specific migration tests (e.g., bisphenol A must not be detectable). Biodegradable materials require submission of migration data and toxicological assessments (such as 90-day rodent studies) through the FCN procedure.
1.2 State Environmental Regulations
In addition to federal FDA regulations, individual US states have varying environmental requirements for biodegradable Chinese take-out boxes. The regulations in key markets are as follows:
California:
SB 1383 (signed in 2016) requires a reduction in compostable materials sent to landfills and sets organic waste recycling targets.
SB 1335 requires that food service packaging used in state facilities must be on the CalRecycle-approved list, and compostable products must be accepted by 50% of organic waste recycling programs and composting facilities (increased to 75% from January 1, 2026).
AB 1201 requires that, starting January 1, 2026, products labeled "compostable" or "home compostable" must be agricultural organic inputs permitted by the USDA National Organic Program (NOP), but this requirement has been extended to June 30, 2027.
SB 1335 requires that food service packaging used in state facilities must be on the CalRecycle-approved list, and compostable products must be accepted by 50% of organic waste recycling programs and composting facilities (increased to 75% from January 1, 2026).
AB 1201 requires that, starting January 1, 2026, products labeled "compostable" or "home compostable" must be agricultural organic inputs permitted by the USDA National Organic Program (NOP), but this requirement has been extended to June 30, 2027.
Washington State:
From January 1, 2024, all compostable products sold must meet ASTM D6400 or D6868 standards, or be made of wood.
Products must be labeled "compostable" on both sides in at least 1-inch green, beige, or brown lettering.
Misleading terms such as "biodegradable" are prohibited.
Products must be labeled "compostable" on both sides in at least 1-inch green, beige, or brown lettering.
Misleading terms such as "biodegradable" are prohibited.
New York State:
GreenNY procurement specifications require compostable products to be certified by BPI, CMA, or an equivalent certification body approved by the state government.
Products must be able to fit into brown organic waste recycling bins.
Products must be able to fit into brown organic waste recycling bins.
1.3 Differences in Biodegradable Product Definition Standards
Different states have varying definitions of biodegradable products, mainly in the following aspects:
Federal Trade Commission (FTC) Definition:
Federal Trade Commission (FTC) Definition:
The FTC's Green Guides provide strict definitions for "biodegradable" and "compostable." Claims of "biodegradable" require proof that the product can completely decompose in a natural or landfill environment within a reasonable timeframe. Since 2022, the FTC has launched a comprehensive revision of the Green Guides, focusing on soliciting feedback on frequently used terms such as "sustainable," "net-zero," and "carbon neutral."
State-level differences:
California requires compostable products to achieve 90% biodegradation within 60 days in industrial composting facilities (ASTM standard requires 180 days).
Washington State requires products to meet ASTM D6400 or D6868 specifications, or be made of wood.
Massachusetts defines "compostable" as bioplastic materials that meet ASTM D6400 or D6868 standards, or products composed solely of wood or fiber-based materials.
Washington State requires products to meet ASTM D6400 or D6868 specifications, or be made of wood.
Massachusetts defines "compostable" as bioplastic materials that meet ASTM D6400 or D6868 standards, or products composed solely of wood or fiber-based materials.
1.4 Regulatory Updates for 2024-2025
The following are important updates to US regulations related to biodegradable Chinese take-out boxes in 2024-2025:
California SB 54 Bill:
Requires by 2032:
25% reduction in all packaging
100% of packaging to be recyclable or compostable
All single-use packaging and single-use plastic food service ware to be recyclable or compostable
California AB 1201 Bill Extension:
In June 2025, CalRecycle announced an extension of the AB 1201 bill's requirement that products must meet USDA NOP requirements until June 30, 2027, providing businesses with more time to adapt.
Washington State New Requirements:
California SB 54 Bill:
Requires by 2032:
25% reduction in all packaging
100% of packaging to be recyclable or compostable
All single-use packaging and single-use plastic food service ware to be recyclable or compostable
California AB 1201 Bill Extension:
In June 2025, CalRecycle announced an extension of the AB 1201 bill's requirement that products must meet USDA NOP requirements until June 30, 2027, providing businesses with more time to adapt.
Washington State New Requirements:
Effective January 1, 2024, all compostable products must:
Be certified by an accredited independent third-party verification body
Meet specific labeling standards to be easily identifiable as certified compostable products
Meet ASTM D6400 or D6868 specifications
Be certified by an accredited independent third-party verification body
Meet specific labeling standards to be easily identifiable as certified compostable products
Meet ASTM D6400 or D6868 specifications
Federal Level Updates:
The FDA plans to publish a proposed rule in October 2025 to revise 21 CFR Parts 170 and 570, involving new requirements for GRAS substances.
2. Analysis of Major Certification Systems
2.1 International Standard Certifications
2.1.1 ASTM Standard Certification System
ASTM international standards are the primary certification standards system for biodegradable Chinese take-out boxes in the United States, including:
ASTM D6400:
Full name: Standard Specification for Labeling of Plastics Designed for Aerobic Composting in Municipal or Industrial Facilities
Scope: Plastic products
Scope: Plastic products
Key requirements:
Biodegradability: At least 90% converted to carbon dioxide within 180 days
Disintegration: Meets ISO 16929 or ISO 20200 standards, 90% disintegration during composting
Ecotoxicity: No adverse effects on the ability of compost to support plant growth, heavy metal content is less than 50% of the limits specified for sludge or compost in the country of origin, germination rate and plant biomass exceed 90%
Disintegration: Meets ISO 16929 or ISO 20200 standards, 90% disintegration during composting
Ecotoxicity: No adverse effects on the ability of compost to support plant growth, heavy metal content is less than 50% of the limits specified for sludge or compost in the country of origin, germination rate and plant biomass exceed 90%
ASTM D6868:
Full name: Standard Specification for Labeling of Plastics Used as Coatings for Compostable Substrates for Aerobic Composting
Scope: Plastics used as coatings or additives combined with paper and other substrates
Key requirements: Similar to ASTM D6400, but specifically for coating materials
Scope: Plastics used as coatings or additives combined with paper and other substrates
Key requirements: Similar to ASTM D6400, but specifically for coating materials
ASTM D8410:
Full name: Standard for Compostability of Cellulosic Fiber Packaging Materials
Scope: Pulp, corrugated materials, cardboard, and other virgin/recycled fiber products, molded fiber packaging (such as egg cartons, food containers)
Scope: Pulp, corrugated materials, cardboard, and other virgin/recycled fiber products, molded fiber packaging (such as egg cartons, food containers)
2.1.2 EN 13432 European Standard
EN 13432 is the European standard for compostable packaging, and is also widely recognized in the US market:
Requirements: Degradation rate exceeds 90% within 6 months under industrial composting conditions (58±2°C), and passes ecotoxicity testing
Relationship with ASTM D6400: The technical requirements are similar, and many certification bodies accept EN 13432 certification as proof of compliance with ASTM standards
Market application: European standard, but also recognized in the United States, especially in international supply chains
Relationship with ASTM D6400: The technical requirements are similar, and many certification bodies accept EN 13432 certification as proof of compliance with ASTM standards
Market application: European standard, but also recognized in the United States, especially in international supply chains
2.2 Industry Association Certifications
2.2.1 Biodegradable Products Institute (BPI) Certification
BPI (Biodegradable Products Institute) is the leading certification body for compostable products and packaging in North America, certifying over 50,000 products. Certification Requirements:
Products must meet ASTM D6400 or D6868 standards.
A new commercial and home compostable certification program will be launched on December 1, 2025, requiring products to fully decompose at lower temperatures in a backyard composting environment.
Ingredients such as PFAS, carcinogens, endocrine disruptors, and heavy metals are restricted to ensure that compost containing certified compostable packaging meets the highest standards.
Certification Process:
Products must meet ASTM D6400 or D6868 standards.
A new commercial and home compostable certification program will be launched on December 1, 2025, requiring products to fully decompose at lower temperatures in a backyard composting environment.
Ingredients such as PFAS, carcinogens, endocrine disruptors, and heavy metals are restricted to ensure that compost containing certified compostable packaging meets the highest standards.
Certification Process:
Material pre-assessment
Selection of a BPI-approved laboratory for testing
Submission of test reports and samples
BPI technical review (approximately 4 weeks)
Certification granted and license agreement signed
Selection of a BPI-approved laboratory for testing
Submission of test reports and samples
BPI technical review (approximately 4 weeks)
Certification granted and license agreement signed
2.2.2 UL Environment Certification
UL Environment offers several certifications related to biodegradable products:
UL 1497 Environmental Claim Verification Program:
UL 1497 Environmental Claim Verification Program:
Used to verify degradation claims for organic/natural materials or products based on controlled waste disposal methods.
Assessment content: Biodegradability or compostability test results, bio-based content testing, and possible or expected disposal methods.
Assessment content: Biodegradability or compostability test results, bio-based content testing, and possible or expected disposal methods.
UL ECOLOGO Certification:
A voluntary, multi-attribute, life-cycle-based environmental certification.
Indicates that the product has undergone rigorous scientific testing and thorough auditing to meet strict third-party environmental standards.
Covered product categories: Paper and plastics (UL 126 Plastic Film Products, UL 2805 Compostable Paper Bags, UL 2826 Cardboard, UL 3420 Plastic Packaging, etc.)
Indicates that the product has undergone rigorous scientific testing and thorough auditing to meet strict third-party environmental standards.
Covered product categories: Paper and plastics (UL 126 Plastic Film Products, UL 2805 Compostable Paper Bags, UL 2826 Cardboard, UL 3420 Plastic Packaging, etc.)
UL 2799 Zero Waste to Landfill Certification:
Requires companies to divert at least 90% of their waste through non-incineration energy recovery methods (e.g., recycling, composting, etc.).
Covers all non-hazardous waste (e.g., plastics, metals, organic waste, etc.)
Covers all non-hazardous waste (e.g., plastics, metals, organic waste, etc.)
2.2.3 SCS Global Services Certification
SCS Global Services offers several environmental certification services:
Biodegradability Certification:
In addition to biodegradability, products must not contain phosphates or be toxic to aquatic species.
SCS only certifies products that meet the OECD "ready biodegradability" definition.
Zero Waste Certification (published April 28, 2021):
Facility Zero Waste Certification: Demonstrates that a facility achieves zero waste to landfill, assessing the percentage of waste diverted from landfills annually. Facilities must demonstrate at least [percentage not specified in original text] 50% of sorted waste is diverted
Zero Waste Project Certification: For entities conducting business in facilities or offices that they do not own or manage
Zero Waste Event Certification: Provides a certification basis for the amount of waste diverted from municipal solid waste landfills during a specific period for events (such as concerts, fairs, and conferences)
Recycled Content Certification:
Products must contain at least 5% recycled content (pre-consumer or post-consumer), based on direct control of the mixing process or mass balance allocation calculation
Complies with the ISO 14021 standard
SCS only certifies products that meet the OECD "ready biodegradability" definition.
Zero Waste Certification (published April 28, 2021):
Facility Zero Waste Certification: Demonstrates that a facility achieves zero waste to landfill, assessing the percentage of waste diverted from landfills annually. Facilities must demonstrate at least [percentage not specified in original text] 50% of sorted waste is diverted
Zero Waste Project Certification: For entities conducting business in facilities or offices that they do not own or manage
Zero Waste Event Certification: Provides a certification basis for the amount of waste diverted from municipal solid waste landfills during a specific period for events (such as concerts, fairs, and conferences)
Recycled Content Certification:
Products must contain at least 5% recycled content (pre-consumer or post-consumer), based on direct control of the mixing process or mass balance allocation calculation
Complies with the ISO 14021 standard
2.3 State-Level Certification Requirements
2.3.1 California CalRecycle Certification
California CalRecycle manages several certification programs related to biodegradable Chinese take-out boxes:
SB 1335 Food Service Packaging Approved List:
All food service packaging used by state facilities must be on the approved list maintained by CalRecycle
Application Process:
Create a WebPass account
Activate the account and log in to the SPARS system
Add company information and create a company profile
Navigate to the "Food Service Packaging Application" tab to submit the application
CalRecycle reviews the application for completeness within 30 days
Once complete, an evaluation is conducted to determine if the product meets the criteria for inclusion on the list
Upon approval, it is added to the list, and the applicant is notified
Material Requirements:
Recyclable materials: PET #1 (non-thermoformed), HDPE #2, uncoated cardboard, clay-coated cardboard, aluminum
Compostable materials: uncoated cardboard, clay-coated cardboard, bagasse/sugarcane fiber molded fiber, bamboo fiber molded fiber
SB 1335 Food Service Packaging Approved List:
All food service packaging used by state facilities must be on the approved list maintained by CalRecycle
Application Process:
Create a WebPass account
Activate the account and log in to the SPARS system
Add company information and create a company profile
Navigate to the "Food Service Packaging Application" tab to submit the application
CalRecycle reviews the application for completeness within 30 days
Once complete, an evaluation is conducted to determine if the product meets the criteria for inclusion on the list
Upon approval, it is added to the list, and the applicant is notified
Material Requirements:
Recyclable materials: PET #1 (non-thermoformed), HDPE #2, uncoated cardboard, clay-coated cardboard, aluminum
Compostable materials: uncoated cardboard, clay-coated cardboard, bagasse/sugarcane fiber molded fiber, bamboo fiber molded fiber
2.3.2 Other State Certification Requirements
New York State GreenNY Certification:
Requirements: Compostable products must be certified by BPI, CMA (Compost Manufacturing Alliance), or an equivalent certification body approved by the state government
Products must be able to fit into brown organic waste recycling bins used for storing food scraps or short-term storage of light, small items
Massachusetts Certification:
Effective January 1, 2027, all retail food establishments must use compostable, recyclable, or reusable food service ware
Compostable product definition:
Products composed solely of wood or fiber-based materials
Complies with ASTM D6400 or D6868 Standard bioplastic materials, or internationally equivalent standards
Washington State Certification:
Effective January 1, 2024, all compostable products must:
Be certified by an accredited independent third-party verification body (such as BPI)
Meet specific labeling standards to be easily identifiable as certified compostable products
Meet ASTM D6400 or D6868 specifications
Be labeled with "Compostable" in at least 1-inch green, beige, or brown font on both sides
Be included in the manufacturer's compliance statement
Requirements: Compostable products must be certified by BPI, CMA (Compost Manufacturing Alliance), or an equivalent certification body approved by the state government
Products must be able to fit into brown organic waste recycling bins used for storing food scraps or short-term storage of light, small items
Massachusetts Certification:
Effective January 1, 2027, all retail food establishments must use compostable, recyclable, or reusable food service ware
Compostable product definition:
Products composed solely of wood or fiber-based materials
Complies with ASTM D6400 or D6868 Standard bioplastic materials, or internationally equivalent standards
Washington State Certification:
Effective January 1, 2024, all compostable products must:
Be certified by an accredited independent third-party verification body (such as BPI)
Meet specific labeling standards to be easily identifiable as certified compostable products
Meet ASTM D6400 or D6868 specifications
Be labeled with "Compostable" in at least 1-inch green, beige, or brown font on both sides
Be included in the manufacturer's compliance statement
3. Specific Certification Standards and Technical Requirements
3.1 Certification Requirements for Food Containers of Different Materials
3.1.1 PLA Food Containers
Polylactic acid (PLA) is the most common biodegradable Chinese take-out box material. Its certification requirements are as follows:
FDA Requirements:
Pure PLA is recognized by the FDA as a GRAS (Generally Recognized as Safe) substance and can be used in food contact applications.
However, additives and colorants in PLA products usually do not meet GRAS requirements and require separate evaluation.
Must comply with the specific requirements of 21 CFR 177.1020 regarding polylactic acid, including purity and biodegradation rate.
The biodegradation rate must reach the minimum percentage required by regulations.
ASTM Certification Requirements:
Must meet all requirements of the ASTM D6400 standard.
At least 90% converted to carbon dioxide within 180 days.
Disintegration test: Material fragments must pass through a 2mm sieve within 12 weeks.
Heavy metal content: Lead, mercury, and other heavy metals must not exceed the specified limits.
BPI Certification Requirements:
In addition to ASTM standards, BPI also requires:
Fluorine content not exceeding 100 ppm (as a substitute indicator for PFAS)
No intentionally added fluorinated chemicals
Material composition confirmed through FTIR (infrared spectroscopy) testing
Ash content test (VOC)
FDA Requirements:
Pure PLA is recognized by the FDA as a GRAS (Generally Recognized as Safe) substance and can be used in food contact applications.
However, additives and colorants in PLA products usually do not meet GRAS requirements and require separate evaluation.
Must comply with the specific requirements of 21 CFR 177.1020 regarding polylactic acid, including purity and biodegradation rate.
The biodegradation rate must reach the minimum percentage required by regulations.
ASTM Certification Requirements:
Must meet all requirements of the ASTM D6400 standard.
At least 90% converted to carbon dioxide within 180 days.
Disintegration test: Material fragments must pass through a 2mm sieve within 12 weeks.
Heavy metal content: Lead, mercury, and other heavy metals must not exceed the specified limits.
BPI Certification Requirements:
In addition to ASTM standards, BPI also requires:
Fluorine content not exceeding 100 ppm (as a substitute indicator for PFAS)
No intentionally added fluorinated chemicals
Material composition confirmed through FTIR (infrared spectroscopy) testing
Ash content test (VOC)
3.1.2 Pulp Molded Food Containers
Pulp molded eco takeout boxes are usually made from natural fibers, and their certification requirements are as follows:
FDA Requirements:
Paper products must comply with the requirements of 21 CFR Part 176 regarding paper and paperboard.
Must not contain more than 1 mg/kg of polychlorinated biphenyls (PCBs).
There are restrictions on the use of recycled fibers.
ASTM Certification Requirements:
ASTM D6400 (if containing a plastic coating) or ASTM D8410 (pure fiber products) can be selected.
Pure fiber products (without plastic or wax additives or coatings) that are more than 98% biodegradable can be considered compostable without specific labeling.
BPI Certification Example:
Pulp folding container (32 oz): BPI certified as 100% compostable, decomposing in commercial composting facilities within 90 days.
The product must state: "Appropriate facilities may not exist in your area."
FDA Requirements:
Paper products must comply with the requirements of 21 CFR Part 176 regarding paper and paperboard.
Must not contain more than 1 mg/kg of polychlorinated biphenyls (PCBs).
There are restrictions on the use of recycled fibers.
ASTM Certification Requirements:
ASTM D6400 (if containing a plastic coating) or ASTM D8410 (pure fiber products) can be selected.
Pure fiber products (without plastic or wax additives or coatings) that are more than 98% biodegradable can be considered compostable without specific labeling.
BPI Certification Example:
Pulp folding container (32 oz): BPI certified as 100% compostable, decomposing in commercial composting facilities within 90 days.
The product must state: "Appropriate facilities may not exist in your area."
3.1.3 Sugarcane Bagasse / Starch-Based Food Containers
Certification Requirements for Sugarcane Bagasse and Starch-Based Eco Takeout Box:
FDA Requirements:
Starch-based materials must meet food contact standards, and total migration levels must meet requirements.
Starch content is typically required to be 40% or higher.
New starch-based formulations require evaluation through the FCN (Food Contact Notification) program.
International Certifications:
Sugarcane bagasse products typically obtain multiple international certifications:
FDA certification (food contact safety)
OK Compost certification (industrial/home compostable)
ASTM D6400 certification (compostability)
BPI certification (North American market)
EU OK Compost Home certification (home compostable)
These certifications demonstrate that the product can completely degrade into organic matter within 90 days under industrial/home composting conditions.
Special Requirements:
Sugarcane bagasse products usually need to pass the BRC (British Retail Consortium) food safety certification.
Some products also need to comply with BSCI (Business Social Compliance Initiative) corporate social responsibility requirements.
FDA Requirements:
Starch-based materials must meet food contact standards, and total migration levels must meet requirements.
Starch content is typically required to be 40% or higher.
New starch-based formulations require evaluation through the FCN (Food Contact Notification) program.
International Certifications:
Sugarcane bagasse products typically obtain multiple international certifications:
FDA certification (food contact safety)
OK Compost certification (industrial/home compostable)
ASTM D6400 certification (compostability)
BPI certification (North American market)
EU OK Compost Home certification (home compostable)
These certifications demonstrate that the product can completely degrade into organic matter within 90 days under industrial/home composting conditions.
Special Requirements:
Sugarcane bagasse products usually need to pass the BRC (British Retail Consortium) food safety certification.
Some products also need to comply with BSCI (Business Social Compliance Initiative) corporate social responsibility requirements.
3.2 Bio-based Content and Heavy Metal Restriction Standards
3.2.1 Bio-based Content Requirements
Different certification systems have different requirements for bio-based content:
USDA BioPreferred Program:
Provides bio-based product certification, allowing products to display the USDA Certified Biobased Product label.
Minimum bio-based content requirements vary for different product categories:
Food service ware: Must contain a minimum of 72% bio-based content.
Disposable tableware: Must contain a minimum of 48% bio-based content.
Currently, more than 3,500 products have received the USDA Certified Biobased Product label.
Other Certification Requirements:
BPI certification does not mandate a minimum bio-based content, but it evaluates the bio-based components of the material.
Some state-level procurement specifications require products to meet specific bio-based content standards.
Companies can voluntarily apply for bio-based content certification to enhance market competitiveness.
USDA BioPreferred Program:
Provides bio-based product certification, allowing products to display the USDA Certified Biobased Product label.
Minimum bio-based content requirements vary for different product categories:
Food service ware: Must contain a minimum of 72% bio-based content.
Disposable tableware: Must contain a minimum of 48% bio-based content.
Currently, more than 3,500 products have received the USDA Certified Biobased Product label.
Other Certification Requirements:
BPI certification does not mandate a minimum bio-based content, but it evaluates the bio-based components of the material.
Some state-level procurement specifications require products to meet specific bio-based content standards.
Companies can voluntarily apply for bio-based content certification to enhance market competitiveness.
3.2.2 Heavy Metal and Chemical Substance Restrictions
The restrictions on heavy metals and chemical substances in biodegradable Chinese take-out boxes are extremely strict:
FDA Requirements:
Lead (Pb): <0.01 mg/kg
Cadmium (Cd): <0.005 mg/kg
Bisphenol A (BPA): Undetectable in most cases, migration limit is 0.05 ppm
Plasticizers: Such as DEHP, must be below [specific limit] 0.05%
Cadmium (Cd): <0.005 mg/kg
Bisphenol A (BPA): Undetectable in most cases, migration limit is 0.05 ppm
Plasticizers: Such as DEHP, must be below [specific limit] 0.05%
ASTM D6400 Requirements:
Heavy metal content must be less than 50% of the limits specified in the country's sludge or compost regulations.
Specific limits vary by country, usually referencing the CFR 503.13 standard.
For example: Zinc 150mg/kg, Copper 50mg/kg, Nickel 25mg/kg, Cadmium 0.5mg/kg, Lead 50mg/kg, Mercury 0.5mg/kg, Chromium 50mg/kg
Specific limits vary by country, usually referencing the CFR 503.13 standard.
For example: Zinc 150mg/kg, Copper 50mg/kg, Nickel 25mg/kg, Cadmium 0.5mg/kg, Lead 50mg/kg, Mercury 0.5mg/kg, Chromium 50mg/kg
BPI Certification Requirements:
Heavy metal limits are 50% of the limits specified in CFR 503.13.
Fluorine content (as a substitute indicator for PFAS) shall not exceed 100ppm.
Intentional addition of PFAS, carcinogens, endocrine disruptors, etc., is prohibited.
Fluorine content (as a substitute indicator for PFAS) shall not exceed 100ppm.
Intentional addition of PFAS, carcinogens, endocrine disruptors, etc., is prohibited.
California Special Requirements:
The total amount of lead, mercury, cadmium, and hexavalent chromium shall not exceed 100ppm.
Total fluorine content (as a substitute indicator for intentionally added PFAS) shall not exceed 100ppm.
Disclosure of whether the product contains chemicals on the Proposition 65 list is required.
Total fluorine content (as a substitute indicator for intentionally added PFAS) shall not exceed 100ppm.
Disclosure of whether the product contains chemicals on the Proposition 65 list is required.
3.3 Degradation Performance and Food Safety Testing Requirements
3.3.1 Degradation Performance Testing Standards
The degradation performance testing of biodegradable Chinese take-out boxes is a core part of the certification:
ASTM D6400 Testing Requirements:
Biodegradation Test (ASTM D5338):
Temperature: 58±2°C
Time: 180 days
Requirement: At least 90% of the material is converted into carbon dioxide.
Test environment: Aerobic composting conditions, humidity 50-55%, pH 6-8
Data recording: CO2 release is recorded every 7 days; complete data for both 90 and 180 days must be submitted.
Disintegration Test (ISO 16929 or ISO 20200):
Time: 12 weeks (84 days)
Requirement: 90% of the material disintegrates into fragments that can pass through a 2mm sieve.
Purpose: To ensure that the product does not cause visual pollution in compost.
Ecotoxicity Test (OECD 208):
Tests the effect of compost on plant growth.
Requirement: Germination rate and plant biomass exceed... 90%
Volatile organic solid content exceeds 50%
ASTM D6868 Test Requirements:
Specifically for coating materials
Test method similar to D6400, but considers the interaction between the coating and the substrate
Must demonstrate that the coating degrades along with the substrate under composting conditions
Biodegradation Test (ASTM D5338):
Temperature: 58±2°C
Time: 180 days
Requirement: At least 90% of the material is converted into carbon dioxide.
Test environment: Aerobic composting conditions, humidity 50-55%, pH 6-8
Data recording: CO2 release is recorded every 7 days; complete data for both 90 and 180 days must be submitted.
Disintegration Test (ISO 16929 or ISO 20200):
Time: 12 weeks (84 days)
Requirement: 90% of the material disintegrates into fragments that can pass through a 2mm sieve.
Purpose: To ensure that the product does not cause visual pollution in compost.
Ecotoxicity Test (OECD 208):
Tests the effect of compost on plant growth.
Requirement: Germination rate and plant biomass exceed... 90%
Volatile organic solid content exceeds 50%
ASTM D6868 Test Requirements:
Specifically for coating materials
Test method similar to D6400, but considers the interaction between the coating and the substrate
Must demonstrate that the coating degrades along with the substrate under composting conditions
3.3.2 Food Safety Migration Testing
Food safety testing ensures that biodegradable Chinese take-out boxes do not migrate harmful substances into food:
FDA Migration Test Requirements:
Overall Migration Limit (OML):
Standard limit: ≤10 mg/dm² or 60 mg/kg
Test conditions: Simulates extreme conditions such as high temperature (100℃), acidic (3% acetic acid), and oily (vegetable oil)
Test duration: Typically 10 days or longer, simulating actual use scenarios
Specific Migration Limit:
Bisphenol A (BPA): Not detectable, migration limit 0.05 ppm
Verified through a 72-hour simulated storage test
Third-party audits show that 78% of biodegradable takeout boxes meet this threshold
Heavy Metal Migration:
Lead (Pb): <0.01 mg/kg
Cadmium (Cd): <0.005 mg/kg
Test method: 24-hour immersion in 4% acetic acid (for ceramics, glass, etc.)
Other test requirements:
Sensory testing: Ensures the material does not alter the taste, odor, or color of food
Microbiological testing: Bacterial colony count must meet food safety standards
Stability testing: Evaluates the stability of the material under different temperature and humidity conditions
FDA Migration Test Requirements:
Overall Migration Limit (OML):
Standard limit: ≤10 mg/dm² or 60 mg/kg
Test conditions: Simulates extreme conditions such as high temperature (100℃), acidic (3% acetic acid), and oily (vegetable oil)
Test duration: Typically 10 days or longer, simulating actual use scenarios
Specific Migration Limit:
Bisphenol A (BPA): Not detectable, migration limit 0.05 ppm
Verified through a 72-hour simulated storage test
Third-party audits show that 78% of biodegradable takeout boxes meet this threshold
Heavy Metal Migration:
Lead (Pb): <0.01 mg/kg
Cadmium (Cd): <0.005 mg/kg
Test method: 24-hour immersion in 4% acetic acid (for ceramics, glass, etc.)
Other test requirements:
Sensory testing: Ensures the material does not alter the taste, odor, or color of food
Microbiological testing: Bacterial colony count must meet food safety standards
Stability testing: Evaluates the stability of the material under different temperature and humidity conditions
3.4 Labeling and Marking Requirements
Biodegradable Chinese take-out boxes have strict labeling and marking requirements:
Federal FTC Green Guides Requirements:
Prohibits false or misleading compostable claims
Unqualified "compostable" claims can only be used if the product is compostable in a home compost pile or device, even if there are no local municipal or institutional composting facilities
Must clearly state composting conditions, such as "Compostable in industrial facilities" or "Suitable for home composting."
State-level labeling requirements:
California AB 1201 Requirements:
Products must meet ASTM standards or OK Compost Home certification
Effective June 30, 2027, starting from [date] (after the extension), the agricultural inputs used must also be USDA NOP-approved organic inputs.
The product and packaging must be clearly labeled "Compostable" or "Home Compostable."
Labels, images, and terminology that may mislead consumers into believing that non-compostable products are compostable are prohibited.
Washington State requirements:
The product must be labeled "Compostable" on both sides in at least 1-inch green, beige, or brown font.
There must be a green stripe at least 0.25 inches wide.
It must be included in the manufacturer's compliance statement.
Misleading terms such as "biodegradable" are prohibited.
BPI Labeling Requirements:
The BPI licensing agreement requires all BPI-certified products and packaging to display the BPI certification mark.
The mark must be used on all consumer-facing and market-facing packaging.
Unless an exemption is granted, it is not permitted to label only the packaging and not the product.
The mark must comply with BPI's trademark usage rules.
General Labeling Elements:
Product name and manufacturer/distributor information
Percentage of bio-based content (if applicable)
Composting conditions (industrial or home)
Certification mark and certification body name
Instructions for use and disposal guidance
Warning information (e.g., "Appropriate facilities may not exist in your area")
Federal FTC Green Guides Requirements:
Prohibits false or misleading compostable claims
Unqualified "compostable" claims can only be used if the product is compostable in a home compost pile or device, even if there are no local municipal or institutional composting facilities
Must clearly state composting conditions, such as "Compostable in industrial facilities" or "Suitable for home composting."
State-level labeling requirements:
California AB 1201 Requirements:
Products must meet ASTM standards or OK Compost Home certification
Effective June 30, 2027, starting from [date] (after the extension), the agricultural inputs used must also be USDA NOP-approved organic inputs.
The product and packaging must be clearly labeled "Compostable" or "Home Compostable."
Labels, images, and terminology that may mislead consumers into believing that non-compostable products are compostable are prohibited.
Washington State requirements:
The product must be labeled "Compostable" on both sides in at least 1-inch green, beige, or brown font.
There must be a green stripe at least 0.25 inches wide.
It must be included in the manufacturer's compliance statement.
Misleading terms such as "biodegradable" are prohibited.
BPI Labeling Requirements:
The BPI licensing agreement requires all BPI-certified products and packaging to display the BPI certification mark.
The mark must be used on all consumer-facing and market-facing packaging.
Unless an exemption is granted, it is not permitted to label only the packaging and not the product.
The mark must comply with BPI's trademark usage rules.
General Labeling Elements:
Product name and manufacturer/distributor information
Percentage of bio-based content (if applicable)
Composting conditions (industrial or home)
Certification mark and certification body name
Instructions for use and disposal guidance
Warning information (e.g., "Appropriate facilities may not exist in your area")
Through reasonable planning and effective execution, companies can successfully enter the US market for biodegradable Chinese take-out boxes and gain a competitive advantage in the rapidly developing sustainable packaging industry. The key is to establish a comprehensive compliance system, select the appropriate combination of certifications, and continuously monitor market and regulatory changes.
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