One year away from the (theoretical) transposition of the SUP Directive against single-use plastics: where do we stand?

July 3, 2021, was the deadline imposed on European Union member states to transpose the Single Use Plastics (SUP) Directive. The directive was necessary to combat the massive presence of polluting plastics, especially in the marine environment. In fact, plastic waste in the sea touches close to 85% of the total amount of all waste in that environment.

According to the observatory activated by essenscia (Belgian Federation of Chemical Industry and Life Sciences), IK (German Association for Plastic Packaging and Coatings) and EuPC (European representative body of plastic processors), the transposition of the Directive currently appears to be sub-optimal and fragmented. The main problem appears to be the lack of homogeneity among member states about the actions taken to reduce single-use plastics: for example, only 13 out of 27 member states have banned straws. There is also the case of those, such as Ireland, who have chosen to go further and adopt more stringent measures than those provided for in the Directive.

This low level of harmonization is an obstacle to the full implementation of what is in the Directive, undermining efforts to combat marine pollution. Not only that, among the main consequences is also the risk that the principle of free movement of goods between states-one of the cornerstone and founding principles of the European Union-will be eroded.


What are the causes of this fragmentation in transposition?

The answer is not single and unambiguous and the framework of responsibilities is complex.
European Plastics Converters (EuPC), a representative body of all supply chains involved in the use, trade and disposal of plastics, identifies among the main causes of this fragmentation the excessive haste in the adoption of the Directive and the delay in the publication by the European Commission of the Guidelines on the transposition of the SUP, which took place on 07/06/21.
In its own document (unfolding the single-use plastics directive), Zero Waste Network (ZWE) points out instead that only a strong monitoring and control system can ensure proper transposition and harmonization between different member states. Indeed, it states that without a common monitoring scheme for all states, fragmentation becomes inevitable.

Italy is a glaring case of a transposition of the Directive that has failed to meet the deadline, and is notable for not having banned some specific products.
In fact, Italy has not banned single-use products made of certified biodegradable and compostable plastics, appealing to certain exemptions cited in Article 11 of the SUP Food Hygiene Directive. For the European Union, however, biodegradable and compostable plastics are not excluded from the definition of plastic. Moreover, this choice partially invalidates priority to reduction and reuse recognized by the Directive itself.

Finally, the case of Italy highlights how, in addition to issues related to the lack of harmonization in transposition, an additional danger lurks behind the SUP Directive. As highlighted by several parties, it is necessary to avert the risk of a mere substitution of materials, which does not primarily counteract disposable products. In the Italian case in particular, the fear is that this transposition will incentivize the replacement of plastics with bioplastics (but not only) without applying real actions to reduce single-use.
Calls for broader regulation of single-use are also emerging in the scientific world. Indeed, the scientific paper Sustainability assessment of a single-use plastics ban argues that a crackdown on single-use, regardless of the material used, would be a more comprehensive action with greater environmental benefits.

To learn more:

Direttiva SUP, il punto sul recepimento (Polimerica)

Stop alla plastica monouso? Ecco cosa prevede l’adeguamento italiano alla direttiva Sup ( 

Read also:

SUP Directive: new European instructions for calculation, verification and communication

Legislative decree to implement the SUP directive goes into effect in January

Reuse perspectives