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The EU’s Single Use Plastics Directive entered into law on 3rd July, but its confused application may harm the integrity of the single market and jeopardise European carbon reduction targets

Brussels, 5th July 2021 – The European Paper Packaging Alliance (EPPA) believes circularity is core to a broader transformation of the European economy and is a key element in achieving climate neutrality and long-term competitiveness.

While EPPA supports the objective of the Single-Use Plastic Directive (SUP Directive) to reduce marine littering, members strongly disagree with the implementation of the legislation that includes products that are over 90% made from paper. Moreover, the EU’s new plans for a modern, resource-efficient and competitive economy are threatened by legislative decisions that are not based on scientific facts. Specifically, EPPA has highlighted that the application of the Guidelines on the SUP Directive creates uncertainty and introduces significant legal and technical challenges.

“It is extraordinary that a piece of harmonizing legislation leads to a fragmented European economic community and a clear increased complexity when the aim is exactly the opposite,” explains Eric Le Lay, President of EPPA. “This will be one of the first consequences of the Guidelines intended to help Member States implement the Directive. They are both unclear and go far beyond the original scope of the Directive. Already, we see how Member States are working on implementing national laws that are very different and often conflict with each other.”

The direction taken by the Commission also results in substantial and harmful unintended consequences. The Guidelines discriminate against low-carbon paper-based packaging, manufactured in Europe from renewable, recyclable and sustainable wood-fibre, effectively favouring non-recyclable tableware made from non-renewable resources primarily manufactured in Asia. Not only does this go against Europe’s objective to stimulate and support a circular economy, but it also challenges the EU’s 2050 carbon neutrality objective.

“We are concerned because including paper-based items within the Directive’s scope is counterproductive in so many ways and leaves room for economies, such as the Chinese and American ones, which are much more harmonized and united,” comments Eric Le Lay, president of EPPA. “Not only will it harm high-value innovation in the European Union but it will be a plastic ban that will simply lead to more plastic. It even goes against the decarbonisation objectives defined by the European Parliament and the Council. As we have amply demonstrated, the replacement of single-use paper packaging with reusable packaging has negative impacts not only on CO2 emissions, but also on many other aspects, in particular freshwater consumption. Water scarcity is a new emergency that affects at least 11% of the European population today.”

By working against paper-based items, the SUP Directive will favour alternatives providing a worse environmental outcome. Reusable tableware is not recyclable and will remain in the environment for a considerable time.
Moreover, a significant proportion is manufactured from non-renewable materials, and has no existing recycling scheme, increasing the burden on the environment.

In January 2021, a study released by EPPA revealed that single-use paper-based food and drink packaging used in European quick service restaurants has a better environmental footprint than reusable alternatives. The Life Cycle Assessment (LCA) study, carried out by independent consultants Ramboll, shows that paper-based packaging tableware has a better environmental footprint than reusable alternatives. The baseline report revealed that reusable tableware generated 2.7 times more CO2 emissions than the paper-based single-use system, consumed 3.7 times more freshwater, produced 2.3 times more fine particulate matter, increased fossil depletion 3.4 times and terrestrial acidification 1.7 times. This study was evaluated by the German TÜV and used current primary data from the paper, packaging and food service sectors to compare the one-year environmental performance of typical disposable and reusable food and beverage containers used in a quick service restaurant for in-store consumption.

“We believe the policies must be based on scientific evidence. LCAs are of benefit to public authorities and citizens, guiding the decision-making process as a practical and effective tool to concretely achieve the goals of the Green Deal,” concludes Le Lay. “Do not forget that packaging plays a fundamental role in protecting food, enabling easy and safe transportation, improving accessibility and ensuring a longer shelf life that can reduce food waste and guarantee high quality and safety to consumers.”

As the European Environment Agency recently confirmed, disposable packaging has “played an important role in preventing the spread of COVID-19.” This is highly relevant, considering that in the first 20 years of the new century the world has already experienced five pandemics, compared with only three in the previous century. In such circumstances the continued use of single use packaging and food service ware provides the only feasible option for maintaining adequate food hygiene, public health and consumer safety.

There are greater risks of transfer of foodborne diseases and cross contamination within reuse systems than in single-use systems. Banning or reducing the use of food service disposables, in the absence of radical significant and unprecedented changes in good hygiene practice, will lead to greater persistence and circulation of foodborne pathogens within the human food chain, and increased risks of human foodborne illness in our community.

The European paper and packaging industry is a global leader in technologies to reduce the polymer content of packaging to a minimum. It is also a leader in the development of sustainable innovative systems using renewable raw materials from sustainable and certified forests, and invests in and promotes recycling, circular economy concepts and high standards in food and consumer safety.

About EPPA
The European Paper Packaging Alliance (EPPA) is a not-for-profit food and foodservice packaging association. The Alliance brings together the leading companies in the fibre-based food and foodservice sector from across Europe.
EPPA members are: Seda International Packaging Group, Huhtamaki, AR Packaging, Smith Anderson, Schisler Packaging Solutions, Stora Enso, Metsä Board, Mayr-Melnhof Karton, WestRock, Iggesund/Holmen, Reno De Medici and Paper Machinery Corporation.