ASTM D6400 and D6868 for Importers of Compostable Molded Fiber and PLA Foodservice Ware

ASTM D6400 is the U.S. specification for plastics and plastic products designed to be composted in municipal and industrial aerobic composting facilities. Its companion, ASTM D6868, covers end items where plastic film or polymer is laminated, extruded or mixed onto another substrate, such as a paper cup with a PLA lining. Neither is a federal regulation. Their force comes from the places that reference them: certification programs, state compostable labeling laws and buyers’ specifications.

For importers of compostable molded fiber and PLA foodservice ware, that makes compostability a documentation problem as much as a materials problem. A plate that would pass in a lab is still a liability if it ships with the wrong logo, the wrong color band for a state that regulates labeling, a fluorine level a certifier rejects, or a resin the FDA food contact route does not cover. And the duty on the same plate swings widely with origin and material.

What ASTM D6400 and D6868 Test

ASTM’s published scope for D6400 (current version D6400-26) covers plastics and products made from plastics designed to be composted under aerobic conditions in municipal and industrial facilities where thermophilic conditions are achieved. Its stated purpose is to set the requirements for labeling materials and products, including packaging, as “compostable in aerobic municipal and industrial composting facilities,” based on whether they compost satisfactorily and biodegrade at a rate comparable to known compostable materials. ASTM notes it is equivalent to ISO 17088.

D6868 (current version D6868-21) applies the same logic to end items that use plastics or polymers as coatings or binders on a substrate, and it has no ISO equivalent. ASTM’s summary names the three characteristics a product must show: proper disintegration during composting, an adequate level of inherent biodegradation, and no adverse impact on the ability of the compost to support plant growth. The specification does not cover the contents of a package, only the package.

Two points follow for sourcing. First, the standard applies to the finished item, not the resin, so a resin supplier’s D6400 claim does not cover a thicker cup, an added mineral filler or a printed lid. Second, both standards are written for municipal and industrial facilities; a product that meets D6400 is documented for those facilities, not for a home compost pile, which matters for the claims discussed below.

BPI Certification and State Compostable Labeling Laws

The Biodegradable Products Institute (BPI) runs the certification most U.S. buyers ask for. BPI uses ASTM D6400 as the base standard for every item and offers optional assessment to D6868 and D8410, the latter limited to cellulosic fiber substrates. Two BPI rules go beyond ASTM and are where imported fiber ware most often fails. Since January 1, 2020, BPI requires a signed statement of no intentionally added fluorinated chemicals and test results from a BPI-approved lab showing no more than 100 ppm total fluorine. BPI also reviews the product and packaging artwork to confirm its certification mark is present.

State law turns those standards into labeling obligations. Washington’s chapter RCW 70A.455 is a good model of what importers face. A product labeled “compostable” in Washington must meet D6400, D6868, D8410, ISO 17088, EN 13432 or an equivalent approved by the Department of Ecology, or be made only of wood or of fiber that is over 98 percent fiber by dry weight with no plastic or wax (RCW 70A.455.040).

• Certification logo: the item must carry the logo of a recognized third-party certifier for the applicable standard.
• The word “compostable” on the item where possible.
• Color cues: compostable plastic foodservice products must be at least partly green, beige or brown, or carry a stripe or band in those colors at least 0.25 inch wide (RCW 70A.455.060); film bags have their own one-inch labeling rule and may not show chasing arrows (RCW 70A.455.050).
• Mirror rule: noncompostable products may not use the colors, labels or terms reserved for compostable ones (RCW 70A.455.070).
• Penalties: up to $2,000 for a first violation, $5,000 for a second and $10,000 for each later one (RCW 70A.455.090).

Who the State Treats as the Producer

Washington assigns compliance to the manufacturer for its own-brand or unbranded products, or to the brand licensee, and only if neither is within the state’s reach, to the party that imports or distributes the product into the state (RCW 70A.455.020). A U.S. importer selling under its own brand is therefore the producer, and the labeling decisions it makes at the factory determine compliance. Other states have adopted labeling laws with their own color, logo and term rules; a national program needs artwork that satisfies the strictest of them, set before tooling and printing, not corrected in a U.S. warehouse.

FTC Green Guides on Compostable Claims (16 CFR 260.7)

Federally, compostable claims are policed as advertising. Section 260.7 of the FTC Green Guides says it is deceptive to misrepresent that a product or package is compostable, and that a marketer needs competent and reliable scientific evidence that all materials in the item will break down into usable compost in a safe and timely manner, about as fast as the materials it is composted with, in an appropriate facility or a home pile.

Two qualification rules matter for D6400 products. If the item cannot be composted safely or in a timely way in a home compost pile, the claim must be clearly qualified; the FTC’s own example is a package that needs a disclosure that it is not suitable for home composting. And if municipal or institutional composting facilities are not available to a substantial majority of consumers or communities where the item is sold, the claim must say so, for example “Appropriate facilities may not exist in your area.”

A D6400 or D6868 report and a BPI certificate are the substantiation file. The qualifiers are a separate drafting exercise that belongs on the carton, the case and the product page, and they have to line up with the state color and logo rules above.

Importing Molded Fiber and PLA Foodservice Ware: PFAS and Food Contact

Compostability and food contact compliance are separate tests, and a product needs both. FDA treats the plate or cup as a food-contact article whose components must each have a lawful route, which our companion guide on food packaging regulations covers in full. Two points are specific to this category.

PFAS: molded fiber needs grease and water resistance, and fluorinated grease-proofers were the traditional answer. FDA announced in February 2024 that PFAS grease-proofing substances for paper were no longer being sold in the U.S. market and, on January 6, 2025 (90 FR 653), declared the related food contact notifications no longer effective. BPI‘s 100 ppm total fluorine limit and state PFAS bans close the same door from the certification and state side. Fiber ware that still relies on fluorinated chemistry fails all three, and the failure is found by testing the shipped product.

PLA: polylactide resins entered the market through food contact notifications. FDA’s inventory lists FCN 178 for NatureWorks LLC (effective January 3, 2002), FCN 475 for NatureWorks high-D PLA (effective February 11, 2005) and FCN 1926 for TotalEnergies Corbion B.V. (effective November 30, 2018), each with its own conditions of use. Under 21 U.S.C. 348(h)(2)(C), an FCN covers only the substance made by the notifier, so a PLA cup is covered by those FCNs only if its resin actually comes from the notifier, within the conditions of use the notification sets. A Chinese or Thai converter should be able to show resin invoices that match the FCN holder.

Neither issue is screened by CBP at entry. They surface in buyer audits, in certification reviews or when FDA samples a shipment, and a failed sample leads to an FDA detention with the goods held at the importer’s cost.

• D6400, D6868 or D8410 test reports on the finished SKU, plus the BPI certificate listing that SKU.
• A no-intentionally-added-PFAS declaration and a total fluorine result at or below 100 ppm from a BPI-approved lab.
• Resin or pulp supplier documentation tying PLA to an effective FCN holder and fiber additives to their FDA routes.
• Approved artwork showing the certifier’s logo, the word compostable, state color cues and FTC qualifiers.

Tariff Lines and Duty for Molded Fiber and PLA Items

Compostability does not change classification. Molded pulp goes to heading 4823.70, bamboo-paper tableware to 4823.61, other paper cups to 4823.69, PLA tableware to 3924 and PLA bags to 3923, all decided by material and form through HTS classification. The table shows candidate lines with MFN and additional duties for China and Thailand as of October 28, 2026. China lines in heading 4823 and PLA bags are on Section 301 List 3 at 25 percent, PLA plates and cups under 3924.10.20 are on List 4A at 7.5 percent, and both origins pay the 12.5 percent Section 301 forced labor tariffs.

The Paper Plate Orders and Molded Fiber

Totals exclude Section 301 product exclusions and antidumping and countervailing duties, and in this category the orders are the bigger number: thermoformed molded fiber products from China and Vietnam, including the 4823.70 lines in the table, are under antidumping and countervailing duty orders published January 27, 2026 (91 FR 3431 and 91 FR 3437). Commerce issued antidumping duty orders on paper plates from China, Thailand and Vietnam on March 20, 2025 (90 FR 13139), and countervailing duty orders on China and Vietnam (90 FR 13135). The scope covers plates cut or formed from paper or paperboard of any fiber, explicitly including bamboo and bagasse, classified under 4823.69.0040 and also 4823.61.0040. It excludes plates molded or pressed directly from paper pulp under 4823.70.0020, as well as paper bowls, buckets and food containers with closeable lids.

That makes the production method a duty question. A bagasse plate molded from pulp is outside the paper plate orders, but if it is thermoformed in China or Vietnam it falls under the separate antidumping and countervailing duty orders on thermoformed molded fiber products published January 27, 2026 (91 FR 3431 and 91 FR 3437); a plate pressed from bagasse paperboard is inside the paper plate orders, and finishing or coating either one in a third country does not take it out. Commerce has also preliminarily found (July 10, 2026) that paper plates completed in Cambodia or Malaysia from Chinese paperboard circumvent the China orders, so importers should keep mill and process documents that support the molded-pulp classification and review antidumping and countervailing duties exposure before switching suppliers. Run specific codes in the China to US tariff calculator, and for program-level sourcing, see our food and beverage logistics page.

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