The Single-use Plastics Directive 2019/904 (SUPD) is part of the EU Action Plan for a circular economy. As part of that plan, the SUPD has been introduced and transposed into Irish Law in July 2021. The goal of the SUPD is the reduction of the impact of certain plastic products on the environment, particularly marine litter.
SUP products are defined as products made completely or partly from plastic and are typically intended to be used just once or for a short period of time before they are thrown away. The SUP Directive restricts certain items from being placed on the market where there is an alternative material available. To see a full list of items that are prohibited, see this Repak post.
As the SUPD applies to products that are made completely or partly from plastic, this has raised questions as to whether or not the SUPD applies to cartons that are manufactured using cartonboard that includes polymers. Typically, polymers are use in cartonboard to give the carton additional properties to make them suitable for food use e.g., to make a carton that is suitable for use in a freezer or for cartons that will contain foods that have a high-water content.
However, the regulation itself does not specify what “partly” means. In Commission
Notice 2021/C 216/01 of 07.06.2021 (“Commission guidelines on single-use plastic products in accordance with Directive (EU) 2019/904 of the European Parliament and of the Council on reducing the impact of certain plastic products on the environment” ) the Commission explains more precisely:
“In the production of many materials, including non-plastic materials, polymers that meet the
definition of plastic in this Directive are often used to achieve specific material properties as well as higher production process efficiencies. Those polymeric materials are often synthetic chemical additives. The use of such polymeric materials, e.g. as retention agents or binders and processing aids in the production of a material which in itself is not plastic, does not result in the single-use product made only of that material to be considered as being made partially of plastic. In particular, paper- and board-based products have in the preparation of this legislative proposal for the Directive specifically been assessed for their potential to serve as a sustainable alternative to single-use plastic products. Consequently, paper- and board- based single-use products made only from paper- and board-based material without a plastic lining or coating are not, in the light of the considerations above to be considered as single-use plastic products in the meaning of the Directive.” (Official Journal of the European Union C 216/8 07.06.2021)
Therefore, it appears that cartonboard that has use polymeric materials in it’s production will not be deemed to fall under the scope of the SUPD.
However, it does state that , “paper-and board-based single-use products made only from paper-and board-based material without a plastic lining or coating are not, in the light of the considerations above to be considered as single-use plastic products in the meaning of the Directive” which may mean that items with a plastic coating or lining may fall under SUPD.
Board manufacturers can provide information as to whether or not a particular board falls under the scope of SUPD as their boards can be tested by accredited testing institutes, such as ISEGA.
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