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EU Single-Use Plastic Directive: what it means for paper manufacture Fig.

Although the project title does not suggest regulations for paper and board, their impact on the design of fibre-based products is signifi cant. Brief outline. Images of plastic waste on beaches and floating patches of plastic garbage in the oceans have raised public awareness. Moreover, consumers are concerned about potential decomposition into secondary microplastics and their uncertain impact on the environment and human health. Based on the “Green Deal”, the Commission now intends to set up a regulatory framework for leading the European economy into a sustainable future by transforming it into a circular economy.

One step toward this goal is the Directive (EU) 2019/904 (Single-Use Plastics Directive) on the reduction of the impact of certain plastic products on the environment. There was a controversial debate on defi nitions and regulatory contents. By July 2021, the directive must be implemented on a national level by all member states, causing many single-use plastic products to be banned within the EU from said date. As of the 3rd July, 2021 a number of other products shall be labelled with a specifi c warning about plastic-induced environmental hazards. Just in time before the end of May 2021, the parties involved agreed on the fi nalised version of the related Commission Guideline C(2021) 3762 regarding the interpretation of the provisions set forth in the Directive.

Fig. 1: Hierarchy of regulations on single-use plastics (as of 1 June 2021)

Which fibre-based products are concerned? The following definitions apply: Single-use plastic product: means a product that is made wholly or partly from plastic and that is not conceived, designed or placed on the market to accomplish, within its life span, multiple trips or rotations by being returned to a producer for refi ll or re-used for the same purpose for which it was conceived. A product that is a single-use product by its design and its material characteristics cannot simply be re-declared a multi-use product.

“Plastic” within the scope of the SUPD means a material consisting of a polymer as defi ned in point 5 of Article 3 of the Regulation 1907/2006 (REACH), to which additives or other substances may have been added, and which can function as a main structural component of fi nal products, with the exception of natural polymers that have not been chemically modifi ed; REACH defi nes polymer as a “substance consisting of molecules characterised by the sequence of one or more types of monomer units [...]”.


Good news first: Single-use paper and board products that are solely made from paper and board and do not include any plastic lining or coating do not count as single-use plastic products for the purposes of the SUPD. The use of synthetic polymer additives such as retention agents, binders and processing aids does not transform paper into a “plastic”-containing product.

But: If a plastic coating or lining is applied to the surface of a paper or board-based material (e.g. as a water/ grease barrier), the resultant product is a composite product that is composed of more than one material, one of which is made of plastics. Thus, according to the current interpretation, papers or boards with a plastic coating or lining are within the scope of the Directive. A lower threshold for a “mass percentage” of plastic(s) does not exist; with the exception of coatings with natural, non-chemically modified polymers (e.g. native starches, MFC, nanocellulose). Regenerated cellulose, e.g. in the form of a viscose, lyocell or cellulose film, is not considered to be chemically modified.

However, polymers obtained by artificial cultivation or fermentation processes in the industry, e.g. polyhydroxyalkanoates (PHAs) or polylactic acid (PLA), are not considered natural polymers, because they are not the result of a polymerisation process that has taken place in nature. Also, chemically modified natural polymers (cellulose acetate, starch ether, or the like) are deemed to be plastics under the regulatory framework when used for single-use products. It seems that the definition of “plastic” as “polymer” according to REACH also contemplates silicones in paper/board coatings which are so far not explicitly regulated in the FCM section of the Plastics Regulation 10/2011.

Fig. 2: Products governed by Single-Use Plastic regulations

Apart from the ban of certain products such as cotton bud sticks, cutlery (especially forks, knives, spoons, chopsticks), plates, straws, beverage stirrers, support sticks to be attached to balloons, food containers made of expanded polystyrene, or products made from oxo-degradable plastic, the Directive also provides for a consumption reduction on certain products and packagings by 2026 as compared to the condition in 2022. These products include cups for beverages, inclusive of their covers and lids, and food containers (receptacles such as boxes for food) intended for immediate consumption either on-the-spot or take-away, if the food is consumed from the receptacle and without any further preparation.

Moreover, the extended producer responsibility requires producers to establish and take over the cost for raising customer awareness for packaging waste and return systems (collection, transport, treatment). Within the scope of raising customer awareness, single-use plastic products must bear a clearly visible, clearly legible and indelible marking “plastic in product” as of 3 July 2021. A transitional provision allows products to be marked with labels for a transitional period ending July 2022. Specific symbols for single- use plastic markings are prescribed (see Fig. 1).

Options for action PTS will gladly be your partner for consultation and testing of alternative product developments that are outside the scope of SUPD but will provide the desired barrier effect against grease, water or migrating substances, and will be food-compliant and recyclable. Laboratory and pilot plants, as well as a broad portfolio of measuring and test services are available. PTS also offers analytical or other services confirming the absence of polymers for the purpose of the REACH Regulation.

Dr. Antje Harling,