Evaluation of the Single-Use Plastics Directive (EU) 2019/904

At Vioneo, as worldwide pioneers of fossil-free plastics production, we welcome the European Commission’s ongoing evaluation of the Single-Use Plastics Directive (SUPD) and its role in reducing plastic pollution while supporting Europe’s transition toward a competitive bioeconomy.

This Directive has played an important role in addressing marine litter and reducing the environmental impacts of certain single-use plastic products. At the same time, the ongoing evaluation provides an opportunity to ensure that the regulatory framework remains effective, innovation-friendly and supportive of the EU’s broader climate and industrial objectives.

Europe’s plastics system is undergoing a profound transformation. Even in a fully-functioning circular economy, new plastic production will remain necessary to meet societal demand for materials in healthcare, food systems, infrastructure and automotive industries. According to the Systemiq Fossil-Free Plastics report (May 2025), Europe is expected to require around 28 million tonnes of new plastics annually by 2050, even with ambitious circularity scenarios (reduce, reuse, recycle).

If the EU is to meet its climate objectives, these remaining volumes must progressively shift from fossil feedstocks to renewable and defossilised sources. Circularity should therefore be understood as the combination of two complementary transitions: closing material loops through recycling and decarbonising the production of new materials through renewable carbon.

For instance, 80–90% of packaging emissions sit upstream, in the materials themselves – yet most regulation focuses downstream on recyclability. While recycling is essential, we can’t recycle our way to net zero if we ignore what packaging is made from.

In this context, one of the most important issues emerging from the evaluation is the need for greater clarity in the regulatory treatment of fossil-free plastics.

The current definition of plastic in the SUPD focuses on the structure of the material rather than the origin of the carbon used to produce it. As a result, plastics produced from fossil feedstocks and plastics produced from renewable or recycled carbon are generally treated in the same way under the Directive.

A clearer and more consistent definition of fossil-free plastics across EU legislation would provide several benefits.

• First, it would improve regulatory clarity and predictability for companies investing in innovative materials and production technologies. Large-scale industrial investments in fossil-free plastics require stable regulatory conditions and clear recognition of renewable-carbon pathways.
• Second, it would allow EU legislation to better reflect the climate benefits of defossilised materials. While the SUPD primarily addresses plastic pollution, other EU policies such as the Circular Economy Action Plan, the Bioeconomy Strategy and the Clean Industrial Deal aim to reduce greenhouse-gas emissions and accelerate industrial decarbonisation. A clearer definition of fossil-free plastics would help align these objectives.
• Third, regulatory clarity would support the development of a European value chain for renewable-carbon plastics. Clear regulatory signals would help attract investment and build the industrial scale needed to compete globally in advanced materials.

A further challenge relates to the differences in Extended Producer Responsibility (EPR) systems, fee levels and product classification, which create uncertainty for producers operating across the EU market.

Current EPR schemes tend to focus primarily on end-of-life characteristics, such as recyclability, while the carbon origin of materials is often not taken into account. Future EPR frameworks should therefore better recognise the use of renewable carbon and fossil-free feedstocks alongside end-of-life performance. In addition, EPR schemes should be more harmonised across the EU, including the introduction of minimum requirements for eco-modulation of fees based on clear environmental criteria. More consistent implementation and enforcement across Member States would reduce compliance burdens, strengthen the functioning of the internal market and provide clearer incentives for investment in sustainable materials.

At Vioneo, we believe that the next phase of the EU’s plastics policy should combine pollution reduction, circularity and industrial decarbonisation. The SUPD has been an important first step in addressing the environmental impacts of single-use plastics. Building on this foundation with clearer definitions, more harmonised implementation and stronger incentives for fossil-free materials would allow the Directive to continue delivering environmental benefits while supporting Europe’s transition toward a competitive fossil-free economy.

We stand ready to contribute our industrial and technical expertise to support this transition.