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Brussels, 1st June 2021 – The European Paper Packaging Alliance (EPPA) – which represents the circular forest fibre-based packaging value chain – is seriously concerned by the adoption of the Commission Guidelines on single-use plastic products required by Directive 2019/904 (“SUP Directive”), which the Alliance believes goes beyond the scope of the Directive

“While we fully agree with and support the objectives of the SUP Directive (SUPD), it is our strong belief that the final release of the SUPD Guidelines is inconsistent with the scope and objectives of the SUP Directive and tainted by serious legal flaws”, said Eric Le Lay, President of EPPA. “In particular, we are concerned that the guidance issued by the European Commission unwarrantedly applies severe and disproportionate measures to single-use paper-based products which utilise thin polymer coating to provide the functionality and safety that European consumers rightly expect.”

“The SUP Directive’s objective is to reduce marine litter and it is difficult to understand how and why products with a low polymer content, such as single-use paper-based products with a thin polymer coating, which are rarely found on the beaches of the Union, are treated more harshly in the Directive than products that are more found in the marine littering and really harmful to the environment. The paper products are among the least commonly found on beaches and, thus, have a marginal tendency to become marine litter. In particular, paper products such as cups, food trays, food wrappers, drink containers are 55th in the list of the Commission Impact Assessment, only account for 0.27% of the marine litter concerned. This is both contradictory and discriminatory.”

“It is also paradoxical that the Commission has approved measures that will lead to a material increase in CO2 emissions, in contrast to the commitment of the European Parliament and EU leaders to decarbonise Europe by 2050,” Le Lay continued. “The Life Cycle Assessment study carried out by Ramboll shows that favouring reusable tableware systems in Quick Service Restaurants would lead to significant increases in carbon emissions and freshwater consumption because of the energy and water needed to sanitize and dry such products before reuse.”

For Information:
EPPA, European Paper Packaging Alliance
Hans van Schaik, Managing Director
Tel. +31 70 312 39 17; E-mail: