Single-Use Plastics Directive
Passed on 5 June 2019, the Single-Use Plastics Directive (SUPD) (E.U. Directive 2019/904) legal text clearly stated its aims but not the exact terms of implementation. Therefore, a guidance document for transposition into national law in each of the E.U. Member States (MSs) was developed by a consultant and released in April 2020. This defines in more detail many of the terms which were left ambiguous in the original text agreed upon by the European Parliament.

For example, the legislation describes the “main structural component”, which you would think signifies the largest amount in a material. In the guidance document however, the “main structural component” is replaced by a “functional component” idea. Essentially, if in absence of this component the product cannot fulfil its function, then it is designated as a main structural component. Because of this crucial change in interpreting the legal text, some have debated the significance of the legislation to their own industries. Afera is monitoring the national applications of the legal text that must be put into place within 2 years of the passing of the original E.U. directive, thus by June 2021.

The division of plastic is another topic which was not defined in the original legislation. It was communicated that the definition under REACH, along with other parameters, would be used. The guidance document went beyond this while not offering absolute clarity, so that even cellulose could be understood to be plastic. This has generated much discussion within the paper industry, and Afera continues to monitor the situation as the legislation is adopted by each of the MSs.


Regulatory Affairs