Interpretation of the EU's "Guidelines for Disposable Plastics" will establish standards for biodegradable plastics

On May 31, 2021, the European Commission published a guidance document-the final version of the "Guidelines for Disposable Plastic Products" to implement EU Directive 2019/904 (SUP Directive) on disposable products.
It will take effect on July 3, 2021
.

Brief description of content:

Brief description of content:

1.
All oxidatively degradable plastics are prohibited, regardless of whether the oxidatively degradable plastics are biodegradable or non-biodegradable
.

2.
The definition of plastics has been re-adjusted to include polymer-based plastic products, bio-based plastics and biodegradable plastics
.

Biodegradable plastics are also classified as plastics because they contain additives

3.
In 2022, biodegradable plastics will be re-evaluated and standards formulated
.

The SUP guidelines will be revised in 2027 to evaluate the standards applicable to marine biodegradable plastics

4.
Strengthen recycling, the design and intention of the product must be able to be used multiple times
.

The "Guidelines for Disposable Plastic Products" are based on the EU SUP Directive 2019/904.
The English name is Commission guidelines on single-use plastic products, or SUP Guidelines for short
.

The release of the SUP guidelines means that Italy’s previous interpretation of bioplastics was rejected

In addition, the European Commission also adopted a decision on "Monitoring and Notification of Fishing Gear Sales and Fishing Gear Waste Recycling
.

" It also stipulates that member states with sea areas must determine the minimum percentage of their own recycling waste plastics before December 31, 2024

Definition of plastic: A material composed of polymers defined in Article 3 (5) of Regulation (EC) No.
1907/20063, which may be added with additives or other substances, and can be used as the main structural component of the final product.
Except for natural polymers that have not been chemically modified
.

In particular, with regard to the most controversial point in the definition, in addition to natural polymers that have not been chemically modified, the document stipulates: plastics made of modified natural polymers, or bio-based, fossil-based or synthetic starting materials The manufactured plastic is not naturally occurring, so it should be handled by this SUP guide
.

Therefore, the adjusted definition of plastics should include polymer-based plastic products as well as bio-based and biodegradable plastics, whether they are derived from biomass or biodegradable over time
.

In short, the definition of plastic covered by the guidelines includes bio-based and biodegradable plastics, whether it is derived from biomass or biodegradable over time
.

In contrast, Italy’s transposition law opened the door to the use of bioplastics, that is, “reusable substitutes cannot be used to replace disposable plastic products listed in Annex B for food contact

On the other hand, unmodified natural polymers produced by natural polymerization processes (regardless of the extraction process) are not prohibited
.

In the example of the SUP guidelines, cellulose and wood or wet milled corn starch extracted from wood meet the definition of a natural polymer

To be defined as "non-chemically modified" polymer, the chemical structure must remain unchanged, even if it undergoes a chemical process or treatment, a physical mineralogical conversion (e.
g.
, removal of impurities) and the like
.

Therefore, regenerated cellulose in the form of viscose, lyocell, and cellulose film is not considered a chemically modified polymer (because the polymer obtained is not chemically modified compared with the introduced polymer), while acetic acid Cellulose is chemically modified (because of the chemical modification of cellulose in the production process)

Is there a way out for bioplastics?

Is there a way out for bioplastics?

The FAQs attached to the document pointed out that there is currently no widely agreed technical standard that can prove that certain plastics can be biodegraded in the marine environment in a short period of time without causing damage to the environment
.

In 2027, the SUP guidelines will be revised, which will involve the evaluation of the technological progress of the standard, especially the marine biodegradability standard applicable to disposable plastic products
.

In the context of the new circular economy action plan, the committee intends to develop a frame of reference for the use of biodegradable or compostable plastics in 2022, based on the assessment of the possible environmental benefits of such plastics, and standards for the application of such plastics
.

Another point relates to the amount of plastic present in the use of disposable products: the guide does not propose a minimum range for the amount of plastic added to disposable products
.

However, the case of plastic-coated paper cups and beverage bottles polycarbonate with barrier function is clearly mentioned

One-time or multi-purpose? To avoid shortcuts, it is not enough to define a multi-purpose article
.
In order not to fall into the “disposable” category, an item must be conceived, designed, and marketed for reuse; in other words, it must be designed and intended to be able to be used multiple times and remain functional before it is finally discarded and disposed of , Physical properties, etc.
are intact; consumers must regard it as a reusable product
.
The relevant design features of the product include the composition of the material, the possibility of cleaning and repairing, so that it can be reused multiple times
.
For packaging containers, the reusable nature can be determined according to the requirements of the packaging and packaging waste guidelines
.

It specifies the types of food containers and whether these containers fall within the scope of sales restrictions
.
Bottle caps and caps: Depending on the shape and material used, the examples show the range of caps and caps
.
If there is a conflict, the SUP instruction takes precedence over the packaging instruction
.
The SUP Directive stipulates that certain single-use plastic products are no longer placed on the EU market: cotton cleaning sticks, tableware, plates, tubes, trays, balloon sticks, and some expanded polystyrene products (cups and containers for food and beverages) and oxidative degradation Plastic products
.

Mitigation measures will be taken for other disposable plastics, such as fishing gear, disposable plastic bags, bottles, beverage and food containers, packaging, envelopes, tobacco filters, sanitary products, wet wipes, from restricting use to reducing consumption goals, and then passing Labeling, expanded producer responsibility schemes ("Polluter Pays Principle"), promotional activities and product design requirements to prevent waste
.