The folding carton containers do not contain plastic according to the Single Use Plastics Directive (European Union (EU) Directive 2019/904, “SUPD”). In fact, single-use products based on paper and cardboard made solely of paper and cardboard based materials do not fall within the scope of the Directive unless they have a plastic coating or coatings whose purpose is to create a barrier, for example against moisture or grease.
Polymeric additives used in paper and cardboard, as well as paints (varnishes), inks and adhesives are exempt from being defined as plastics, since they do not constitute a main structural component.
However, “plastic free” claims are made inconsistently for example in the scope of the SUP Directive, so all associations belonging to PRO CARTON, of which ASPACK are a member, support the use of use clearer definitions, to prevent confusions.
La SUP defines single-use plastic products as products made in whole or in part from plastic, which are primarily intended to be used only once. For the purposes of the SUP, "plastic" shall mean a material composed of a polymer as defined in point 5 of article 3 of Regulation (EC) No 1907/20063, to which additives or other substances may have been added and that can function as a main structural component of final products, with the exception of natural polymers that have not been chemically modified.
At the European guidance level, there is no minimum plastic content in the EU definition of what is considered plastic, although some Member States do apply a threshold percentage.
The lack of clarity about what is the correct interpretation of the requirements for a structural layer, especially as it differs from other current regulations, is leading to an increasing use of alternative standards to demonstrate what could be considered plastic free. This is creating a skewed competitive landscape both in terms of how similar products can be marked as containing plastics or not where appropriate or how they can be promoted in the marketplace, but also in terms of single-use plastic-related taxes in the markets. that may be incurred depending on different interpretation of plastic-free conditions.
Article 3(43) of the proposed Regulation on Packaging and Packaging Waste follows a similar definition for plastics to that used in the SUP. However, the boundary between the fiber-based packaging categories “paper and board” and “composite packaging where the majority is paper/board” is not clear. Low amounts of plastic have no impact on the recycling process of fiber-based packaging and therefore the reason for defining the categories should not be just the plastic content.
