Packaging industry is confused – five problems about SUP directive
The implementation of the European Union’s Single-Use Plastics (SUP) directive is confusing to manufacturers of fibre-based packaging. They are hoping that the legislation will be clarified through subsequent work.
The European Union’s Single-Use Plastics (SUP) directive came into effect in 2019 and has since then been gradually implemented by national legislation in the Member States (MSs).
The directive affects manufacturers of fibre-based packagings because plastic is often used in such packagings as a protective layer, or barrier. In a paperboard cup, for example, plastic prevents the cup from becoming soggy, and in food packagings it protects the food from oxygen and the environment from food oils.
The packaging industry stresses the nature of EU directives as something not directly implemented by the Member States. Instead, its provisions are implemented by national legislation, and the MSs have a certain leeway in how this is done.
In other words, a directive leaves some things to be decided by the MSs, and its provisions are generally also implemented in slightly different ways The same applies to the SUP directive.
’There are some countries that have not yet adopted any legislation implementing the directive,’ says Alexey Vishtal, Head of Novel Packaging Development of the Austrian MM Group.
The group owns and operates the Kotkamills plant in Finland.
Since the directive leaves some freedom to the Member States, Vishtal would like to make sure that the national legislation will fit in with the business activity, to avoid unnecessary difficulties for the business.
If interpreted appropriately, the directive could drive the adoption of paper-based solutions in line with the positive environmental outcomes that the directive envisions.
’If interpreted appropriately, the directive could drive the adoption of paper-based solutions in line with the positive environmental outcomes that the directive envisions,’ says Vishtal.
On the other hand, the SUP directive wins no prizes for unambiguity.
’Some of the definitions used in it are vague and can be interpreted in several ways,’ says Maija Pohjakallio, VP Climate and Circular Economy of Metsä Group.
Annika Sundell, EVP Innovation, Business Development and Sustainability at Walki, says that implementing the SUP directive has been challenging.
’I’d consider this to be a development project’
MM Group considers the directive as ’work in progress’.
’I’d consider this to be a development project. We still lack clarity on how different EU member states will apply financial instruments to single-use paper packaging that includes a small percentage of plastic. Once we know this, we can pool our experience and define best practices across the geographies where we do business,’ Vishtal says.
Vishtal continues that this is especially important for a company like the MM Group, which manufactures packaging materials in several countries.
’What we need above all is a targeted harmonisation of the approaches to introducing SUP-related fees in different countries. So far, the interpretations adopted by MSs have caused no problems, and we hope that future revisions of the directive will result in unified approaches across Europe,’ Vishtal says.
Vishtal is confident that the MSs will initiate a harmonization process by 2028 at the latest.
Sundell considers that the different interpretations of the directive across MSs can only be seen as a substantial problem.
’It will lead to inconsistencies and complicate a uniform implementation of the directive,’ Sundell says.
Businesses consider the SUP directive to give rise to five significant problems.
Problem 1: What is plastic?
Ultimately, the provisions of the directive must be implemented. It is therefore surprising that the definition of plastic in the SUP directive is one of the things that MSs have interpreted in different ways.
Sundell says the definition has been difficult to interpret.
’The definition of plastic in the directive allows different interpretations. Moreover, different countries have applied the directive in different ways, which has further complicated the situation,’ says Sundell.
The definitions of plastic in the SUP directive and in the Packaging and Packaging Waste Regulation (PPWR) passed at the 2025 turn of year are identical.
Problem 2: What is a single-use packaging?
The SUP directive is supposed only to deal with single-use packagings and not, for example, storage containers. Still, such innovations as caps or lids that remain attached to the packaging are being seen in storage containers as well. A good example of this are one-litre or even bigger beverage packagings and bottles, which are hardly likely to be emptied all at once.
In fact, one of the things the directive does not pay sufficient attention to is packaging size.
’Is a one-litre milk carton a single-use packaging, or is it a storage container? How many of us open the carton, drink it empty at one go and then dispose of it in the nearest bush?’ asked Ali Harlin, Research Professor at the Technical Research Centre of Finland VTT in an earlier article on the SUP directive in Forest.fi.
Problem 3: What is a plastic product?
According to the SUP directive, even a small amount of plastic in a product makes it ’a product containing plastic’, even if by far the greatest share of the product consists of fibre-based material. Despite this, says Pohjakallio, some MSs do not consider a product to be a product containing plastic if the plastic content is below a specific threshold.
’So, MSs also differ from each other on what is or isn’t considered a plastic product,’ Pohjakallio says.
’The directive has not been interpreted uniformly, which has led to confusion. This hasn’t been beneficial for the industry or its credibility,’ says Sundell.
A definition not included in the SUP directive, but seen for the first time in the PPWR,is hat of a ’mix-material packaging’: in a packaging made of two different materials, for example, the minimum share of either material must be five percent. If the share of either is below this, the item is classified as a ’mono-material packaging’.
’We hope this will harmonize the practices,’ says Pohjakallio.
One of the packaging types designed to be banned in restaurants from 2030 onwards are single-use plastic serving packagings for food to be consumed in the restaurant. ’Without clear definitions, it will be difficult to interpret certain prohibitions in the directive,’ says Pohjakallio.
MM Group considers that defining a precise threshold can lead to undesired results.
’If plastic were allowed to be, say, 10% and the rest was wood fibre, for example, one way to solve the problem would be to increase the amount of wood fibre in packaging, which would only lead to over-packaging,’ Vishtal says.
Instead, according to Vishtal, the directive should provide guidelines on the adoption and use of recyclable materials.
’MM Group’s innovation agenda aims to bring such materials on to the market. The directive could support such initiatives by giving clearer and more uniform guidelines,’ says Vishtal.
Problem 4: Turtle logo
The SUP directive requires all single-use products containing plastic to display the ’turtle logo’. In Finland, the logo is printed on all single-use paperboard cups, for example. This is because the directive defines the coating of the cups to be plastic.
According to Pohjakallio, the logo is liable to mislead the consumer about recycling, for example. In Finland, plastic-coated paperboard cups should be recycled as paperboard, but the turtle logo points to a completely different direction: recycling as plastic.
Vishtal believes that the purpose behind the logo is to increase customer awareness of the harmfulness of plastic waste. However, a bigger problem is the uncoordinated proliferation of various environmental labels.
’The consumer may not understand the message behind these labels. Are they saying the turtle is dead? Is it because it has eaten plastic garbage? And what then – what does the label tell consumer to do with the packaging after use?’ asks Vishtal.
Problem 5: Insufficient attention to work done by the packaging sector
Pohjakallio points out that many Eu projects pay insufficient attention to the development of collection and recycling systems. Yet the packaging sector itself has invested a lot in these.
An example is 4evergreen, an alliance of 110 companies, including businesses along the entire life span of fibre-based packagings – from forest to products, designers, retailers and recyclers.
’This alliance has set the ambitious goal that 90 percent of fibre-based packagings will be recycled by 2030.To reach this goal, there is collaboration on several fronts,’ says Pohjakallio.
The current recycling rate of paper and paperboard packagings in the EU is 83.2 percent.
MM Group points out that good cooperation between companies and legislators is not a new phenomenon: it began as far back as the mid-1990s with the Extended Producer Responsibility (EPR) programme. Cooperation between the EU and businesses on how to define ’single use’ and ’plastic packagings’ would, in Vishtal’s opinion, construct a credible pathway to reducing plastic waste. Packaging manufacturers could be confident that it pays to look for solutions to replace plastics, for thanks to the collaboration, their sustainability can be assumed even in the long run.
Read more: Eight familiar uses of wood pulp: could you manage your daily life without them?
