The Single-Use Plastics Directive of June 2019: what it covers, and what it means for plastic strapping

On 5 June 2019 the European Parliament and the Council adopted Directive (EU) 2019/904 on the reduction of the impact of certain plastic products on the environment. It was published in the Official Journal on 12 June 2019, and Member States have until 3 July 2021 to transpose it.

For packaging buyers, the obvious question is whether it affects the plastic strap on their pallets. The short answer is that strap is not on the directive’s list. The longer answer is worth knowing, because one provision applies to all plastic products and others may change the market for recycled PET.

What the directive covers

Article 2 sets the scope: the single-use plastic products listed in the Annex, products made from oxo-degradable plastic, and fishing gear containing plastic. The Clifford Chance briefing of July 2019 explains that the Commission’s proposal targeted the single-use items most often found on European beaches, together with lost and abandoned fishing gear.

Measure	Examples in the directive	Relevance to strapping
Market restrictions (Article 5, Part B)	Cotton bud sticks, cutlery, plates, straws, stirrers, balloon sticks, expanded polystyrene food and drink containers and cups	None of these is strapping
Oxo-degradable plastics (Article 5)	Any product made from oxo-degradable plastic	Applies to every product, so it can apply to strap or film
Consumption reduction, marking and producer responsibility	Food containers, drinks cups, wet wipes, tobacco products and others listed	Consumer items, not transport packaging
Recycled content (Article 6(5))	PET drinks bottles at least 25% recycled plastic from 2025; drinks bottles at least 30% from 2030	Indirect: demand for recycled PET
Separate collection (Article 9)	Drinks bottles: 77% by 2025 and 90% by 2029	Indirect: supply of collected PET

Why strap is not on the list

Article 3(2) defines a single-use plastic product as one not conceived to make multiple trips or rotations by being returned for refill or re-use for the same purpose. Strap that is cut off and discarded after a single use may well meet that definition. But the directive does not apply to every product that meets the definition. It applies to the products listed in its Annex, and strap is not among them.

Strap that holds unit loads together for handling and transport generally falls within what EU packaging law calls transport packaging. Directive 94/62/EC defines transport packaging as packaging that makes it easier to handle and transport a number of sales units or grouped packs and prevents damage in transit. Obligations on transport packaging come from that directive and national packaging law, not from the single-use plastics list.

The provision that does reach every product

The ban on products made from oxo-degradable plastic is not limited to the Annex. It covers plastic containing additives that make it break into fragments through oxidation. If any strap, stretch film or shrink hood in your supply chain is sold with such additives, it falls within the ban once national rules apply it from 3 July 2021.

Most strapping buyers will find the answer is simple, but it should be confirmed in writing rather than assumed. Ask suppliers of strap and film to state whether oxo-degradable additives are used.

Indirect effects worth watching

Recycled PET demand. The bottle targets in Article 6(5) give drinks producers a reason to secure recycled PET. Recycled PET is also used in other products, including some PET strap. The directive does not say what will happen to price or availability, and nobody can promise an outcome in July 2019. What a buyer can do is find out whether its strap contains recycled PET and from which source.

Collection. Article 9’s separate collection targets aim to raise the quantity of drinks bottles collected, which works in the opposite direction on supply. The net effect is a market question, not a legal one.

National rules. The Clifford Chance briefing notes that certain Member States have announced national rules on single-use plastics. Transposition laws may go further than the directive in some countries, so each destination needs its own check.

Practical steps in July 2019

• Record the material of each strap you buy: PET, polypropylene or woven polyester.
• Ask for a written statement on oxo-degradable additives in strap and film.
• If a supplier claims recycled content, ask how the content is defined and how it is documented.
• Keep packaging waste obligations under national packaging law on your compliance list, separate from the single-use plastics measures.
• Avoid describing strap as “compliant with the single-use plastics directive”; it is outside the listed scope, which is a different statement.
• Diary 3 July 2021 for national transposition in each country you ship to.

For PET strap or woven strap enquiries, state the material, nominal width and any recycled-content or additive information you need documented, and send it through the enquiry page.