1.    Webinar meeting with stakeholders as the discussion and planning forum

At the 4 hours webinar meeting for the discussion of implementing Directive (EU) 2019/904 (SUP Directive) was organized by Ramboll, DELOITTE, IEIC, PROGNOS, WOOD and IEEP on April 3rd, 2020. The focus was to continue discussion and draw conclusions on the results of stakeholder responses for the inquiries made since October 2019 for identifying and describing the products covered by the Directive.

The overall target of SUP directive is to prevent the pollution of marine ecosystem caused by non-digestible non-degradable synthetic plastics. Those may exist as various physical forms including small particles, as well.

It was agreed that by 3th July2020 Commission provides national authorities and economic operators with technical and legal clarifications, along with illustrative examples to ensure harmonised interpretation of single-use plastic products in accordance with the SUP Directive. Various parts include guidance on objectives and scope, general terms and definitions, single-use plastic product definitions and supporting information.

Important questions for Finnish pulp and paper-based product industries deal with definition of plastics and level of chemical modification of natural polymer cellulose under processing to change molecular mass and crystalline structure. ECHA reported that there are three alternatives to find out suitable interpretation:

  • Strict interpretation: no modification is allowed, even during the extraction process.
  • Medium strict interpretation: no intentional change occurs in any stage of the manufacturing process.
  • Less strict interpretation: referring to the end stage of the manufacturing process

In the case of the end stage consideration ECHA also proposed, that in the final product the polymer (cellulose) should be reverted back to the original state. That is actually taking place when regenerated cellulose fibres are produced from dissolving cellulose.

Additional to the definitions of natural product and natural polymer, the main functional component is important for manufacturers of packaging, food wrapping and cutlery products, which may contain besides of pulp, also plastics in remarkable concentrations.

The targeted products under SUP Directive were discussed in five  groups consisting of balloons and balloon sticks, beverage containers and cups, cotton bud sticks, cutlery products, food containers, lightweight plastic carrier bags, packets and wrappers, plates, sanitary towels, tampons, straws, tobacco products with filters and wet wipes. The published Part 1 of the Commission first draft for discussion with member states deals with General scope and definitions.

2.    Cellulose chain in pulp&paper and fibre industries

Cellulose is separated from wood chips by mechanical, chemical, and chemo-mechanical methods. Chemical methods (sulphate/Kraft and sulphite) affect mainly on wood lignin to dissolve it in alkali and separating it from wood. Alkaline lignin (black liquor) solution is used to produce energy making the factory self-sufficient, and in many cases, factories supply energy for outsiders, as well. Many lignin products, such as raw lignin for glues, lignosulphonate, vanillin, sitosterol, and active carbon are also made from black liquor.

During non-chemical, mechanical grinding and refining processes high amount of energy is needed, followed by softening degradation of lignin and separation of pulp fibres from each other. Some degradation of cellulose and lignin molecules is taking place in this case, as well.

It is important to notice, that wood-based cellulose products, such as pulp and viscose fibres behave quite safely under marine conditions. Natural cellulose waste from ground and marine plants undergoes “chemical modification” caused by enzymes, water, heat, and UV radiation resulting changes in molecular structure, which is not reverted directly to the original state.  Only after degrading cellulose to sugars, it can be converted back to original state by photosynthesis with chlorophyll, sunlight, and water.

Thus, it is reasonable to further modify the less strict interpretation for the “not chemically modified” natural polymer by leaving out the claim for back-reverting. Despite of that, all measures must be kept on for minimising the marine litter from pulp and cellulose products.

Wood cellulose (pulp) is presently recycled by using deinking processes up to 70% from newspapers and other printed products. It is used increasingly in many of the food serving and packaging products to replace oil-based non-renewable synthetic plastics. Coated and laminated paper with plastics is technically superior in packaging and wrapping, but problematic in the light of SUP Directive, because plastics are included in main functional component. By now, there are no “de-inking” methods for coated paper packaging/wrapping products, even though they have been studied in laboratory level. Some studies have found nanocellulose (NFC) as an effective coating substance for food packaging paper, however NFC is far more too expensive for such kind of consumer products. Thus, the main way of preventing marine pollution relates to waste management and incineration for energy production of products after use.

According Part 1 of the Commission first draft for discussion with member states,  paper- and board‐based single use products would generally not be considered as single use plastic products in view of the above considerations. However, a polymeric coating or lining is applied to the surface of paper and board material achieving higher water and oil resistance. This is considered as able to function as a main structural component. It provides the necessary water and fat resistance to paper‐based consumption beverages or moist and fat containing food plates.

Plastic coating and lining of otherwise paper‐based products for the purpose of the Directive is seen as creating multi‐layered products. Plastic coatings and linings have been deleted by the legislators from the final text of the Directive.

Paper‐based products without a plastic lining or coating have been identified as an available and more sustainable alternative to single‐use plastic products in the Environmental Impact Assessment. In contrast, for example, paper cups with a plastic layer have not been identified as single‐use non plastic alternative option, as they are described in the Impact Assessment as not plastic free and therefore no marketing restriction was introduced for single‐use plastic cups. Furthermore, single‐use plastic plates are subject to marketing restriction in the SUP Directive, because paper plates without a plastic lining or coating are available as a single‐use non plastic alternative.

One challenging alternative may be offered by different cellulose (non-derivative) films, which are produced by direct solubilisation of cellulose into aqueous (Viscose, Biocelsol) or organic solvents (Lyocell). They could be used instead of plastics in coating and laminating layered structures.

Regenerated cellulose (viscose) is used in sanitary towels, tampons and wet (dry) wipes. Part 1 of the Directive provides guidance to determine whether the fibre in question fullfils the criteria for the exception for “natural polymers that have not been chemically modified”. Wet wipes, which are made of natural polymers which are not chemically modified, including cotton, and regenerated cellulose, i.e. viscose and lyocell, fall outside the scope of the SUP Directive.


The measures discussed for the reduction of marine litter include reduction of consumption, restrictions on placing on markets, separate collection, and awareness rising on waste management.

3.    Brief presentation of SUP Directive Draft (EU) 2019/904 Part 2/2

While Part 1 of the Commission first draft for discussion with member states deals with General scope and definitions, the second part provides further clarification of the SUP Directive criteria for various products seen important in reducing marine pollution.

First, an overview will be provided of the requirements and descriptions laid down in the Directive for specific product group, followed by guidance on how to distinguish single use from multiple use products, and a product overview. Additionally, explanation is described of the difference between the product in case and other similar product categories in the SUP Directive.

In product category “Food Containers” pulp cellulose containing products include carton box containing soups and carton box containing milk and wine are in the scope of single-used plastics due to the synthetic polymer content.

In product category “Beverage containers” beverage bottles, cups for beverages are receptacle products with a capacity of up to 3 litres, used to contain beverages, such as milk and wine. Beverage cups include drinking vessel receptacles, open at the top, with or without a cover or a lid, sold empty or containing beverages are made from plastics and cellulose carton. In both cases when cellulose/pulp is used, the important factor for SUP is the content of plastic. In case of “natural polymers that not been chemically modified” 100% as the raw material of a beverage container, the product is not regarded as single-used plastic. Carton plastic cups with inner plastic coating for hot or cold beverage (with or without cover or lid) are regarded as single-used plastic.

The product category of “Packets and Wrappers” includes packets and wrappers made from flexible material containing food that is intended for immediate use. There is the exception for “natural polymers that have not been chemically modified” when they are used 100% as the raw material. There is no mention of single-use paper products, which typically are above 50 microns. Thus, in case Kraft pulp is interpreted as natural cellulose, which is not chemically modified, paper packets and wrappers are not regarded as single-used plastics. Paper products with inner plastic coating for improving technical properties are regarded as single-used plastics.

The product category of “Lightweight plastic carrier bags” includes bags with a wall thickness below 50 microns typically for single use. The category mentions again the exception for “natural polymers that have not been chemically modified”. There is no mention of single-use paper bags, which typically are above 50 microns, up to 150 microns (Kraft paper). Thus, in case Kraft pulp is interpreted as natural cellulose, which is not chemically modified, paper bags are not regarded as single-used plastics.

The category of “Cotton bud sticks” refers to a product made for hygienic and medical use consists of short stick with a small amount (or wad) of cotton glued at one or both ends, where the stick is made of plastics, wood or cellulose. For medical applications EU Guidance for the application of the Council Directive 93/42/EEC on Medical Devices15 provides guidelines on the classification of medical devices for the purposes of risk assessment. Only plastic stemmed, double-tipped cotton bud stick products are classified into SUP directive, whereas non-plastic stemmed cotton bud stick, plastic stemmed stick, single-tipped specimen collection swab for medical use and plastic, reusable ear cleaning stick for multiple use are excluded from SUP directive. Cotton can be replaced by regenerated cellulose because viscose and lyocell fibres are accepted as “natural polymer that have not been chemically modified”.

The category of “Cutlery, plates, straws and stirrers” refers to implements used for mixing, serving, and eating food. The products under the category typically are forks, knives, spoons, chopsticks and plates, straws, and beverage stirrers. Plates are widely made from cellulose carton coated with plastic film for technical functionality. Additionally, tablecloths and napkins are typical single-use products and often made from short-cut viscose nonwovens with wet-laid method and from pulp-viscose blend by dry-laid method. Both product use mainly acrylate binders for strengthen the product. All these fiber-based product fall under SUP Directive because of using plastics as strengthening material. Non-plastic single-use cutlery plates, straws, stirrers without plastic liners /coatings are excluded from the products under SUP Directive.

The category of “Balloon and sticks” typically refers to a single-use non-porous bag of light material, such latex balloons for domestic use or application, mylar or foil balloons intended for domestic use or application and plastic balloon sticks intended for domestic use. On the other hand, reusable, plastic, inflatable toys, and products including resealable valve, plastic balloon stands and balloons for industrial uses and applications e.g. hot-air balloon and weather balloon are excluded from the coverage of the Directive.

Product category of “Sanitary towels (pads), tampons and tampon applicators” can be defined as hygiene products used to absorb and retain menstrual fluid, generally intended to be disposed of after single use. They consist of liquid absorptive fibres, such as viscose, cotton and pulp, and most often plastics, which are capable of retain liquid inside during the use, thus belonging under SUP Directive. Super absorbants (SAP) (acrylate basis) are used in powder or fibre form to bond the liquid in gel form. Largest volume of products are baby diapers, adult incontinence diapers and personal hygiene products for women. Sanitary towels (including panty liners), or tampons which do not contain plastic, reusable (washable) menstrual products and are excluded from the control of Directive. Respectively, excluded are washable cloth pads, reusable menstrual cup, period underwear and reusable tampons.

Product category of “Wet wipes” is defined as pre-wetted personal care and domestic single-use wipes being within the scope of the SUP Directive, whereas industrial wet wipes should be excluded. The use of wipes and wet wipes has been increased due to their versatility in cleaning. Personal care use includes baby wipes, skin cleansing wipes, facial/cosmetic wipes, and intimate care wipes e.g. for female hygiene purposes and toilet tissue wipe. Domestic use includes wipes used to remove stains and clean surfaces such as floors, bathrooms, kitchens, furniture, windows, TV and computer screens, disinfection wipes intended for domestic use, and spectacle cleaning wipes, car wipes intended for domestic use and pet wipes intended for domestic use. Industrial wet wipes used in industries, such as automotive, electronics and computers, food industry, janitorial, manufacturing, engineering and maintenance wipes, optical industry, printing, transportation. Wet wipes intended for professional use include medical/healthcare wipes such as hospital grade disinfectant wipes to clean and disinfect surfaces and intended for industrial or professional use and  medical/healthcare wipes such as patient care wipes for human hygiene purposes and intended for industrial or professional use.

Dry wipe e.g. not pre-wetted before placed on the market are excluded from the scope of Directive.

In product category “Tobacco products with filters; filters marketed for use in combination with tobacco products” the product is a tobacco that can be consumed and consist of tobacco and contains a filter: e.g. a cigarette or cigar. Product can be a separate filter for use with tobacco products: e.g. a filter tip or mini filter. The products being in the scope the Directive are cigarette or cigar with filter and separate single use filters for use in combination with tobacco products. Cellulose acetate short-cut fibres are mainly used in tobacco filters. Even when natural cellulose is substituted with natural acetic acid (anhydride) substitution of cellulose, it is not fulfilling the definition of “natural polymers that have not been chemically modified” and thus is in the scope of Directive. Electronic tobacco, heated tobacco and loose tobacco are not in the scope of Directive.




  1. First draft for discussion with Member States: Commission guidance in accordance with Directive (EU) 2019/904 of the European Parliament and of the Council of 5 June 2019 on the reduction of the impact of certain plastic products on the environment, 89 pp.
  2. First draft for discussion with Member States: Commission guidance in accordance with Directive (EU) 2019/904 of the European Parliament and of the Council of 5 June 2019 on the reduction of the impact of certain plastic products on the environment, 18 pp.