The final version of the EU’s Single Use Plastics Directive (Directive (EU) 2019/904) included a provision that by summer 2020 the EU would release a set of guidelines for the different countries to help write legislation for the transposition of the directive. These guidelines were to provide clear information on exactly which and what items would fall under the directive, and under what article – from an outright ban to awareness raising to reduction targets.

Due to the COVID-19 crisis, these guidelines were delayed several times and up until now have not been officially released. However, on September 9th another meeting of the workgroup for these guidelines took place, and the draft version has been leaked. As these guidelines are only a draft, the specific determinations in the text cannot be taken as final, however it provides much more clarification and a good indication on what does, and what does not fall under the directive.

See below a few highlights:

What happens to plastic lined or coated cardboard?

The original text of the SUP Directive explained that Single Use items that have plastic as a “main component” would be included, and now the draft clarifies this further.

Single-use plastic product listed in the Annex of the Directive fall within its scope also if they are made partly from plastic – regardless of the amount of plastic contained. The Directive does not envisage any de minimus threshold for the plastic content in a product

Later on in the text of the draft, this is specifically mentioned to apply to cardboard plates with a plastic coating:

However, a polymeric coating or lining that is applied to the surface of the paper-/board material for the purpose of the final product to provide resistance against water and fat is to be considered as a main structural component.

The preliminary conclusion here is that almost all currently available disposable plates will be banned under the directive – however Moulded Fiber plates as BFG is offering do not contain any plastic coating and therefore will not be included in the ban.

Clarifications about Bio-Plastics

There has been a lot of confusion over the last 12 months whether products made from “Bio-Plastics” would be exempt from the Directive. For this as well the draft includes clear clarification:

Plastics manufactured with modified natural polymers, or plastics manufactured from bio-base, fossil or synthetic starting substances are not naturally occurring and should therefore be addressed by this Directive. The adapted definition of plastics should therefore cover polymer-based rubber items and bio-based and biodegradable plastics regardless of whether they are derived from biomass or are intended to biodegrade over time.

There are still more questions than answers, and even these clarifications raised more issue than they resolved, but a start is a start and all of us in the Disposable Catering Ware trade will have to our best to be as prepared as we can for when the SUP Directive becomes law and active.

If you, as a valued partner of BFG Packaging, are interested to see the complete documents for yourself, please do not hesitate to contact your BFG relation and we will provide the links to the documents.