EU Single-Use Plastics Directive: What It Means for Packaging Buyers

The EU Single-Use Plastics Directive comes up constantly in sourcing conversations, but a lot of the confusion isn’t about what it bans — that part is fairly settled — it’s about what’s changed since it took effect, and what newer EU packaging rules layer on top of it. Here’s where things actually stand.

What the Directive Bans

Directive (EU) 2019/904 has applied across EU member states since 3 July 2021. It prohibits placing certain single-use plastic products on the EU market where non-plastic alternatives are readily available: plastic cutlery, plates, straws, stirrers, cotton buds, balloon sticks, oxo-degradable plastics, and expanded polystyrene (EPS) food containers and cups.

The practical effect for foodservice packaging is straightforward for the banned categories themselves — conventional plastic straws, cutlery, and EPS containers are off the table for EU sales. But the exemption for alternative materials is narrower than “compostable material = automatically not plastic”: under the Directive’s own definition, a polymer counts as plastic if it has been chemically modified, regardless of whether it is bio-based or biodegradable. European Commission guidance on Directive (EU) 2019/904 states that biodegradable and bio-based plastics — including PLA — are considered plastic under the Directive and are not automatically exempt from the single-use plastic bans. Only natural polymers that have not been chemically modified, such as unlaminated paper and comparable uncoated fiber materials like plain bagasse, fall outside the Directive’s definition of plastic. In practice, paper and uncoated bagasse products are generally treated like paper and sit outside the ban, while PLA components — and any plastic or PLA coating or lining on a paper or bagasse product — need to be evaluated against the Directive’s plastic definition on a product-by-product basis, not assumed exempt because the base material is marketed as compostable. See the European Commission’s guidance on the Single-Use Plastics Directive for the underlying definition.

The Newer Layer: Packaging and Packaging Waste Regulation (PPWR)

Regulation (EU) 2025/40, the Packaging and Packaging Waste Regulation, entered into force on 11 February 2025 and began general application across all 27 EU member states on 12 August 2026 (Article 71), replacing the nearly 30-year-old Packaging Directive (94/62/EC). Because it’s a regulation rather than a directive, it applies uniformly without needing separate transposition into each country’s national law. Not every obligation in the Regulation takes effect on that same date, though — several of its most-discussed requirements, including the headline recyclability rules, phase in years later. Here’s what applies when, article by article.

Requirements that apply from 12 August 2026

• PFAS restriction (Article 5): food-contact packaging may not be placed on the EU market if it contains PFAS above 25 ppb for any single non-polymeric PFAS substance, 250 ppb for the sum of non-polymeric PFAS, or 50 ppm total fluorine (covering polymeric PFAS). This applies from 12 August 2026 with no grace period for existing stock.
• Hazardous substance limits: combined lead, cadmium, mercury and hexavalent chromium in packaging capped at 100 mg/kg, applying from the same 12 August 2026 general-application date.
• EPR producer registration (Article 44): Article 44 requires each Member State to maintain a national producer register and requires producers to register in each Member State where they first make packaging or packaged products available. The timing and procedure are not created by one uniform EU-wide registration portal on 12 August 2026. Under Article 44(1), Member States have 18 months from the entry into force of the first implementing act adopted under Article 44(14) to establish the national registers required by the PPWR. Existing national EPR registration rules may continue to apply in the meantime. Producers should therefore confirm the currently applicable registration process and deadlines separately in every destination Member State.
• General authorized representative (Article 17): a producer may — but is not required to — appoint an authorized representative established in the EU, by written mandate, to carry out specified packaging-conformity and market-surveillance-cooperation tasks on its behalf; a single such appointment can cover all 27 member states. This is a general, permissive provision, not a universal mandatory requirement, and it is separate from the EPR-specific representative requirement below.
• EPR authorized representative (Article 45(3)): a distinct, Extended Producer Responsibility-specific representative requirement. An EU-established producer that sells packaging into other member states without a local establishment there must appoint an EPR representative in each such state. For producers established outside the EU, most independent compliance-sector summaries describe the obligation to appoint an EPR representative as something individual member states may choose to impose (“member states may provide”), rather than a single automatic EU-wide mandate; a minority of sources characterize it as universally mandatory. Buyers working with non-EU suppliers should confirm the specific rule in each destination member state rather than assume one EU-wide answer.

Requirements that phase in later — not from 12 August 2026

• Recyclability “by design” (Article 6(2)(a)): packaging must be designed so the resulting material can be recycled into secondary raw material capable of substituting virgin material. This applies from 1 January 2030, or 24 months after the Commission’s delegated act setting the detailed design-for-recycling criteria enters into force (that delegated act is due by 1 January 2028), whichever is later — not from the 2026 general-application date.
• Recyclability performance grades and the 70% threshold (Article 6 and Annex II): from the same 1 January 2030 date, packaging is graded on a recyclability scale, and packaging that doesn’t reach at least Grade C (broadly, at least 70% recyclable under the Annex II methodology) is classified as not recyclable and barred from the EU market. The bar tightens to Grade A/B only from 1 January 2038.
• Recyclable “at scale” (Article 6(2)(b)): a separate, later condition requires packaging to actually be collected, sorted and recycled at scale in practice. This applies from 1 January 2035, or five years after the relevant implementing act, whichever is later.
• Recycled-content and packaging-minimization rules: minimum recycled-content requirements for plastic packaging, and packaging-minimization rules such as capping empty space in e-commerce packaging, also begin phasing in from 2030.

The PPWR additionally restricts specific single-use plastic packaging formats — grouping film at point of sale, individual condiment portions, small hotel toiletries, and packaging for food and drink consumed on-site in hotels, bars, and restaurants. For compostable packaging specifically, the regulation requires it to meet industrial composting standards, and member states can mandate compostable formats where composting infrastructure already exists.

Article numbers and dates above reflect the Regulation’s published text and related Commission guidance; some delegated and implementing acts referenced above (for example under Article 6(4)) had not yet been finalized at the time of writing, so implementation detail may still evolve. Buyers should confirm current requirements with their own compliance counsel.

What This Means for Sourcing Decisions

For buyers already sourcing paper, PLA, or bagasse packaging, the regulatory direction reinforces rather than disrupts existing sourcing choices — these material categories sit outside the conventional-plastic bans and align with the PPWR’s compostability and recyclability requirements. The more relevant question for procurement teams is documentation: verifying that a supplier’s compostability claims are backed by recognized certification (BPI/ASTM D6400 in the US framework, EN 13432 in the EU framework), and that wood-fiber materials carry legitimate chain-of-custody certification like FSC. Selling into the US too? Our companion guide to US state-level plastic packaging laws breaks down the parallel, but different, patchwork of EPR, PFAS, and polystyrene rules across US states.

Regulatory requirements around PFAS in food-contact packaging are also tightening across the EU, so it’s worth confirming with any supplier — Corncomp included — that food-contact materials are tested and documented accordingly.

Certification Checklist for EU-Bound Packaging

• FSC Chain of Custody for wood-fiber materials (paper, kraft, cardboard)
• BPI Compostable (ASTM D6400) or equivalent EN 13432 compostability certification for PLA and bagasse
• Food-contact compliance documentation (EU AP 2002, FDA, or LFGB depending on market)
• ISO 9001:2015 or equivalent quality management certification

Corncomp’s publicly available certification records and product-level certification guidance are summarized on our Certifications page. For order-specific documentation, contact our team. For a material-by-material breakdown of which claim applies to which product, see our guide to PLA vs bagasse vs FSC paper, and for how to confirm those claims are genuine, see how to verify a supplier’s sustainability certifications are real.

This article summarizes publicly available regulatory information as a general reference and isn’t legal advice. Buyers should confirm current requirements with their own compliance counsel or the relevant EU authority before finalizing sourcing decisions.