BRUSSELS, Belgium – On 19 December 2025, the Belgian Competition Authority has published an informal opinion of the President under Article IV.19 of the Belgian Code of Economic Law giving its blessing to a proposed joint initiative by Comeos and KOFFIECAFE to commercialise only industrially compostable coffee pods in Belgium starting on 12 August 2026, ahead of the EU Packaging and Packaging Waste Regulation’s deadline in 2028.
The suppliers represent 90% of the market, while the agreement pushes forward a statutory deadline provided for by Regulation (EU) 2025/40 on Packaging and Packaging Waste (RPPW).
Based on the information provided, the opinion concludes that this initiative pursues a clear sustainability objective, is comparable to an agreement ensuring compliance with binding EU requirements, and does not appear to pose a significant risk of restricting competition.
According to the law firm Van Bael & Bellis, the President of the BCA – applying the principles contained in the “horizontal cooperation agreement guidelines” of the European Commission (Commission) and the draft Guidelines for Sustainability Agreements of the BCA – authorised the joint commitment on the following grounds:
- The joint commitment is a sustainability agreement that reduces waste, decreases the contamination of the waste streams that are not supposed to contain coffee pods, and gives a boost to recycling efforts.
- The joint commitment allows waste management companies to adapt their systems to the new make-up of waste from coffee.
- The joint commitment does not restrict competition among roasted coffee suppliers because it (i) only moves forward by a year and a half a requirement already provided for by the RPPW; (ii) will not substantially reduce the choice of coffee pods because suppliers compete on a range of factors unaffected by the agreement, including price and quality of the coffee; (iii) will cause the cost of waste treatment to come down; (iv) does not involve the exchange of sensitive business information; and (v) has a limited scope which does not affect other competitive aspects of sustainability such as the method employed to produce the coffee.
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