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March 26, 2021 04:02 PM

EuPC says exemptions to the SUP Directive are not the way forward

Karen Laird
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    Albert Einstein famously said that ‘We can't solve problems by using the same kind of thinking we used when we created them.’

    That logic, while indisputable, tends nevertheless to be defeated when industry interests are at stake.

    Which is precisely why, wrote the EU level trade association European Plastics Converters -  EuPC  - in a recent op-ed published on EurActiv, we need to be very careful in making exceptions to the Single-Use Plastic Directive.

    The SUP Directive was adopted with the express purpose of tackling the problem of the waste plastic polluting the world’s oceans. It represents a key action for the achievement of UN Sustainable Development Goal 14, which calls for the conservation and sustainable ‘use of the oceans, seas, and marine resources for sustainable development’.

    The plastics industry, wrote EuPC, is committed to achieving the highest environmental standards set at EU level in order to allow a complete transition to a circular economy and to guarantee a high level of environmental protection.

    In recent weeks, however, various voices have been heard to question the range of items that should be covered by the SUP Directive. The paper industry, in particular, has raised concerns regarding the inclusion of polymer-coated paper products, such as cups. The limited amount of plastics used in such items, said the paper industry, does not warrant their falling within the scope of the Directive.

    As EuPC noted, neither the Single-Use Plastics Directive nor its implementing acts – already published or currently at a drafting stage – set an upper limit on the quantity of plastic used in a product, above which the product should be considered to fall under the directive.

    The reason for this omission was because the EU legislator concluded that the amount of plastic in a product should not be the decisive factor, but instead, the functionality of the plastic in the item - and the likelihood of the product becoming litter after its use.

    In other words, the question is first: could this item still be functional if the polymeric component were lacking? And then, is the item likely to be improperly discarded after its use?

    In the case of paper cups, obviously, incorporating plastic into the pulp during its manufacture or adding a coating or lining is essential to provide to resistance grease or water.

    However, as EuPC wrote, ‘single-use paper/paperboard products bearing a polymeric substance, whether embedded in the pulp or used as lining/coating are generally perceived as more environmentally-friendly items and this misconception increases with the decrease of the plastic component in the product. Therefore, paper/paperboard products are arguably more likely to be littered in the environment'. Consumers, said the association, will not realise that the paper-based product they think is 100% paper  is actually almost certain to contain some kind of plastic. This unawareness is very likely to significantly increase the possibility of  'improper discarding behaviour'.

    The Single-Use Plastic Directive offers a useful means to achieve a high level of environmental protection, EuPC noted, adding:

    ‘The entire industry, across all sectors, should interpret the Single-Use Plastics Directive as a driver of modernisation and a boost to the research for truly green substitutes that will be able to guarantee both high levels of environmental protection and high standards for products’ performance.’

    The fight against marine litter should be the main concern of the industry as a whole. Exempting certain products from the Directive because there are currently no replacements able to guarantee comparable high standards of performance is hardly going to help tackle the problem. It is that kind of thinking that got the oceans into this mess in the first place.

    Einstein said something else that also made a lot of sense. ‘It takes a touch of genius–and a lot of courage–to move in the opposite direction’. The question is, of course, does the EU have sufficient amounts of either?

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