Starch Europe Position on Single Use Plastics
Starch Europe welcomes the European Commission’s evaluation of Directive (EU) 2019/904 on the reduction of the impact of certain plastic products on the environment (SUPD). This exercise provides an opportunity to assess the Directive in light of implementation experience and developments in related EU legislation.
In this context, implementation across Member States, together with developments such as the REACH microplastics restriction and the Packaging and Packaging Waste Regulation (PPWR), has highlighted structural inconsistencies in the current framework, particularly regarding the structure-based definition of “plastic” and its implications for certain bio-based materials.
Key Points:
- The SUPD definition of “plastic” is primarily structure-based and does not sufficiently account for environmental persistence or biodegradability.
- As a result, renewable and biodegradable materials, including certain starch-based coatings, may be treated identically to persistent fossil-based plastics.
- Implementation experience shows diverging interpretation across Member States, creating legal uncertainty and fragmentation in the Single Market.
- In addition, coherence issues have emerged with other EU frameworks, including the REACH microplastics restriction and the Packaging and Packaging Waste Regulation (PPWR).
- The evaluation of the SUPD provides an opportunity to clarify and refine the definition, improving proportionality and regulatory coherence while maintaining environmental ambition.
To read the full position, click here:
April 19, 2026
