The full submission to the SUPD evaluation can be found here within the EU “Have Your Say” process:

The practical reality across Europe is already showing clear inconsistencies:

⚠ Several legal proceedings concerning SUPD implementation are currently pending in Germany.
⚠ The Netherlands has abandoned its former “0.0% approach” and is now re-evaluating the previous methodology.
⚠ France withdrew its 0.1% threshold due to practical non-feasibility and is likewise reassessing its approach.
⚠ In Poland, according to the current situation, identical products are being assessed differently depending on the region — products accepted in the north are in some cases rejected in the south.

The result is a fragmented regulatory landscape — in some cases even within individual Member States.

For businesses, authorities and consumers alike, this situation is neither practical nor sustainable in the long term.

Our proposal

Therefore, we call for 1. a comprehensive, EU-wide harmonised quantitative threshold, combined with 2. an analytically verifiable assessment logic as well as 3. a stronger alignment with actual recycling realities and circular economy principles. Instead of “0.0% interpretations”, there is a need for 4. clear, transparent and enforceable criteria that can be applied consistently and independently verified.

Fibre-based solutions containing minimal, technically unavoidable polymer fractions should not be regulated in the same way as conventional plastic-dominant single-use products.

From our perspective, a harmonised quantitative approach is essential, for:

• authorities
• industry
• consumers
• legal certainty in enforcement
• the promotion of innovation
• a functioning European single market

and, above all, for the environment. Only clear, harmonised and practically verifiable rules can ensure consistent and effective implementation across Europe.

Most importantly, the necessary technical and regulatory foundations already exist, including standardised analytical methods, established recycling processes and independent third-party verification.

We welcome further technical exchange with industry, the recycling sector, the paper and packaging industries, authorities and additional stakeholders.

About flustix

The organisation, founded in Berlin in 2017, offers six distinct flustix seals: The flustix LESS PLASTICS – MIN. xx% PLASTIC-FREE seals certify, in collaboration with recognised testing laboratories and accredited certification bodies, the entire product as well as either its packaging or the product itself. Products that refrain from using microplastics are transparently labelled with the PLASTIC-FREE – Product Content Microplastic-Free seal. The flustix RECYCLED trustmark certifies recyclates, semi-finished goods, and products with recycled content, including plastics, metals, and glass. flustix RECYCLABLE independently communicates the recyclability of packaging. The flustix seals serve as a guide for consumers and thereby support companies in pursuing a sustainability-focused business strategy and ensuring credible sustainability communication.

Der Beitrag SUPD: Driving Innovation Instead of Holding It Back erschien zuerst auf FLUSTIX.

Why Europe now needs a clear polymer threshold – and why the SUPD cannot function without it

The Single-Use Plastics Directive (SUPD, EU 2019/904) is approaching a turning point. Officially, its evaluation is not scheduled until 2027, but unofficially the Commission has already been working intensively on revisions for months. And this is urgently needed.

Because in practice, since its introduction in July 2021, it has become clear: with the current binary definition of plastics – “contains plastic = SUP” – it is impossible to regulate a modern, innovation-driven market. The result is misclassification, diverging national interpretations, and a climate of uncertainty that especially restrains those who are developing sustainable solutions.

The fact remains: market analyses show that the consumption of single-use packaging such as paper cups, trays or plates has not decreased since 2021. The SUPD does not remove these products from the market – it merely regulates them in a more complex way.

Innovation meets a patchwork of regulations

While classic PE-coated cups clearly fall under the SUPD, the situation for modern, strongly polymer-reduced or nearly polymer-free functional systems is completely different:

• Some Member States recognise these innovations and do not classify them as SUP.
• Others treat identical products as SUP – despite very low polymer content and good recyclability in the paper stream.

The result: technological progress is colliding with a European patchwork that slows rather than enables environmentally friendly innovation.

In many conversations over recent months, I increasingly hear the same issue from companies: they want to continue advancing innovative, polymer-reduced materials – technologically and strategically. At the same time, they openly question whether this path is economically worthwhile under the current SUPD framework. Several companies have told me that, despite better recyclability and lower environmental impact, conventional PE coatings are again being considered. The reason is simple: if an innovative and more expensive material remains regulatory unclear while potentially causing the same or even higher costs as the conventional alternative, innovation becomes a risk factor.

Science, NGOs, industry and new EU regulations: rarely so aligned

Remarkably, there is now a broad consensus:

• environmental organisations such as WWF or Rethink Plastic
• scientific institutes
• large parts of the converting industry
• and the new PPWR regulation

all point in the same direction: a quantitative, scientifically defined polymer threshold is necessary.

Paper science provides a clear foundation for this. According to scientific literature, polymer components of around 1.0% are technically necessary for the production of paper and paperboard alone in order to manufacture a stable and processable paper or board sheet. This includes, among others, binders, dispersing and functional additives, wet-strength agents and auxiliary substances used in paper production.

– Please find the scientific derivation by clicking on the link. –

Modern, innovative material systems, such as high-performance fibre-based cup systems, already achieve polymer contents below 1.0% by mass today – including barrier functionality, high recyclability and stable performance.

The PPWR shows where Europe is heading

With the 95/5 rule (at least 95% fibre content), the PPWR sends a clear signal in the packaging sector, following the current technical possibilities of recycling fibre-based materials. Europe is moving away from binary material definitions and towards quantitative, measurable criteria.

The SUPD, however, continues to operate in a black-and-white mode – an approach that no longer reflects market realities and will be untenable by 2027 at the latest.

Member states compared: Why 0.0% cannot work

Netherlands: The political ideal of complete polymer freedom (0.0%) proved technically unfeasible in practice. A cup without a minimal functional layer is not a cup. The rules were withdrawn and are now being reconsidered.

France: The planned 0.1% threshold (trace content) was suspended with the bilan d’étape in November 2025, as 0% plastic (or only trace amounts) is not technically or industrially realistic by 2026. The matter is now under renewed review and will be decided accordingly.

Italy: A 10% value stands in stark contrast to zero-approaches elsewhere and further increases European inconsistency.

Germany: Clear rules for conventional, polymer-intensive coatings contrast with unclear classifications – and even potential disadvantages – for modern, innovative coating systems.

Poland: Overly ambitious, strict 0.0% requirements without a valid analytical methodology lead to enforcement problems — in practice even to a regional patchwork and, consequently, increasing legal uncertainty.

Europe is more fragmented on the SUPD today than ever before.

Conclusion: A clear polymer threshold is the only way out of the stalemate

Europe needs a harmonised, measurable and enforceable threshold for polymer-containing fibre-based products under the SUPD. A limit just above the scientific minimum – that is, in a range slightly above 1.0% polymer mass content – would:

• enable and drive innovation rather than impede it
• make the SUPD workable
• create legal certainty and planning security
• ease enforcement burdens on authorities
• stimulate investment in sustainable material systems
• actually support the directive’s environmental objectives
• and return valuable material to the circular economy

As long as this harmonisation is missing, companies have only one path:
Test. Document. Certify.

Only then can modern, polymer-reduced systems be reliably distinguished from classic SUP products – and companies be protected from the consequences of a contradictory legal framework.

Europe stands at a decisive point.
The revision of the SUPD will determine whether it becomes a driver of sustainable innovation – or remains a brake.

About flustix

The organisation, founded in Berlin in 2017, offers six distinct flustix seals: The flustix LESS PLASTICS – MIN. xx% PLASTIC-FREE seals certify, in collaboration with recognised testing laboratories and accredited certification bodies, the entire product as well as either its packaging or the product itself. Products that refrain from using microplastics are transparently labelled with the PLASTIC-FREE – Product Content Microplastic-Free seal. The flustix RECYCLED trustmark certifies recyclates, semi-finished goods, and products with recycled content, including plastics, metals, and glass. flustix RECYCLABLE independently communicates the recyclability of packaging. The flustix seals serve as a guide for consumers and thereby support companies in pursuing a sustainability-focused business strategy and ensuring credible sustainability communication.

Der Beitrag Opinion: SUPD at a turning point: Four years of legal uncertainty now require clear rules erschien zuerst auf FLUSTIX.

Cash for Circularity – how independent recycled-content certification turns your effort into financial gain

The new EU Packaging and Packaging Waste Regulation (PPWR) forces companies to fundamentally redesign their packaging. Those who tackle this transformation now should take a broader view: France and Spain are simultaneously creating concrete financial incentives for the use of recycled plastics. The decisive point, however: only certified recycled content is recognised.

France: Bonus payments from 2026 – up to €1,000 per tonne

In France, a national bonus system will apply from 1 January 2026 for packaging with demonstrably recycled plastic content. The Arrêté of 5 September 2025 provides bonuses of €450 to €1,000 per tonne – depending on the material and application.

The key requirement:
The recycled content must be confirmed by an independent, accredited certificate.

With flustix RECYCLED, based on EN 15343 and ISO 22095, eligibility for the bonus is automatically fulfilled.

Spain: Tax savings already active today

Spain has levied a plastic tax of €0.45/kg on non-recycled plastic in non-reusable packaging since 1 January 2023.
Since 2024, recycled content is only recognised if certified according to UNE-EN 15343.

Companies with flustix RECYCLED automatically meet this requirement – and reduce their tax burden immediately.

Example calculation

A company uses 1,000 t of plastic packaging per year, 30% of which is recycled content (300 t):

• France: 300 t × €550/t = €165,000 bonus
• Spain: 700 t virgin material × €0.45/kg = €135,000 tax savings

Requirement in both countries: independently certified recycled content.

Why flustix RECYCLED?

flustix RECYCLED is:

• recognised across the EU
• compatible with UNE-EN 15343 (Spain) and the requirements of the French Arrêté
• auditable via ISO/IEC-17065-accredited certification bodies
• legally robust and internationally interoperable
• B2C-ready (on-pack, online, EmpCo-compliant including “M-Code”)

This means the programme covers all regulatory interfaces – from PPWR verification to EmpCo compliance and national bonus and tax systems.

The fast track to financial advantages

1. Analysis: Assess materials, recycled content and supply chain – flustix supports this process.
2. Certification: Documentation, chain-of-custody and audit via accredited partners.
3. Benefit:
   • Spain: immediately through reduced tax
   • France: bonuses payable from 2026

Those who design their packaging PPWR- and EmpCo-compliant today can realise real financial benefits tomorrow.
flustix RECYCLED makes this possible – with clear documentation, European recognition and a measurable return on sustainability.

Further information (PDF): Info: New regulations on the use of recyclates in France and Spain – secure tax beneftis now!

About flustix

The organisation, founded in Berlin in 2017, offers six distinct flustix seals: The flustix LESS PLASTICS – MIN. xx% PLASTIC-FREE seals certify, in collaboration with recognised testing laboratories and accredited certification bodies, the entire product as well as either its packaging or the product itself. Products that refrain from using microplastics are transparently labelled with the PLASTIC-FREE – Product Content Microplastic-Free seal. The flustix RECYCLED trustmark certifies recyclates, semi-finished goods, and products with recycled content, including plastics, metals, and glass. flustix RECYCLABLE independently communicates the recyclability of packaging. The flustix seals serve as a guide for consumers and thereby support companies in pursuing a sustainability-focused business strategy and ensuring credible sustainability communication.

Der Beitrag Certifying with flustix RECYCLED – Save Tax & Benefit from Bonuses erschien zuerst auf FLUSTIX.

EmpCo creates clear rules and new financial opportunities

The 27 EU Member States are currently transposing the “Empowering Consumers for a Green Transition” Directive (EmpCo, EU 2024/825) into national law, with a final deadline of 27 March 2026. In parallel, pressure from consumer protection bodies and NGOs is increasing significantly: too many environmental claims are misleading, leading to a growing number of cases taken to court. Penalties are reaching record levels – and companies are obliged to scientifically substantiate environmental and sustainability claims.

At the same time, many companies recognise that EmpCo not only creates obligations but also opens genuine economic opportunities: those who already use robust, independent evidence can secure six-figure financial benefits today.

EmpCo Reaches Europe’s Largest Markets – Implementation in the Final Stage

National transposition is visibly progressing across the largest EU economies.
Germany has published a draft government bill to amend the UWG. Italy has adopted the legislative act, placing verifiable sustainability claims at its core. Spain has presented one of the most comprehensive approaches with the Anteproyecto de Ley de Consumo Sostenible. Poland is adjusting consumer law, while Denmark is integrating EmpCo directly into national law via Lovforslag L 147.

This brings the key date of 27 September 2026 closer: from this point on, sustainability claims must be scientific, contextual and verifiable.
Companies that prepare in advance not only achieve compliance but also gain a credible advantage with authorities, business partners and consumers.

Greenwashing Has Consequences – Courts Send Clear Signals

NGOs and consumer protection bodies are increasingly acting on their supervisory and corrective role – and courts are already ruling along EmpCo and upcoming Green Claims Directive principles:

• In France, Shein received a fine of 40 million euros for unlawful environmental claims.
• At European CPC level, the beverage industry (including Coca-Cola, Danone, Nestlé Waters) was required to revise its “100% recycled” and “100% recyclable” claims.
• In Italy, the authority AGCM imposed a 1 million euro fine for greenwashing.
• In Germany, Deutsche Umwelthilfe (DUH) is driving a new wave of lawsuits:
  • The Frankfurt Regional Court prohibited Apple from advertising the Apple Watch as “CO₂-neutral”.
  • The Bochum Regional Court ruled against Deichmann for misleading sustainability claims.
  • More than 30 additional proceedings are pending.

Companies that use vague, exaggerated or unsubstantiated sustainability claims face major financial and legal risks.

EmpCo, PPWR, Green Claims Directive: Obligation, Opportunity and Cost Lever

The PPWR requires companies to transparently document packaging components, recycled content and recyclability. These very data points are a central foundation for EmpCo and the upcoming Green Claims Directive (GCD).

In EU Report COM(2025) 871 final, the Commission explicitly assigns the GCD to the 2026 work programme – a clear signal that the GCD continues as an active initiative, closely embedded within the EmpCo framework.

Companies that implement PPWR now and integrate EmpCo and GCD at the same time – instead of sequentially – avoid duplicated processes.
Those who wait risk an expensive “salami-tactic” rollout:
2025 PPWR, 2026 EmpCo, 2028 GCD – each time new data structures, new teams, new system implementations, new follow-up costs – and that costs money.

EmpCo as a Financial Opportunity: Unlocking Tax Savings and Bonuses

Concrete financial advantages are opening up in parallel:

• Spain: Certified recycled content – e.g. via flustix RECYCLED – immediately and permanently reduces the plastic tax of 450 €/t for packaging.
• France: The EPR bonus system provides premiums between 450 and 550 €/t for packaging, exclusively with certified recycled content from January 2026 onwards.

Independent, accredited certification thus becomes an economic lever:
It strengthens credibility, reduces greenwashing risks and pays off directly – through reduced taxes, lower compliance costs and substantial bonus payments.

Conclusion:

EmpCo is reshaping the rules of sustainability communication – while simultaneously creating financial advantages for companies that act early.
Those who combine PPWR implementation with the EmpCo logic and rely on robust, independent evidence reduce risks, save costs and strengthen their competitive position.

About flustix

The organisation, founded in Berlin in 2017, offers six distinct flustix seals: The flustix LESS PLASTICS – MIN. xx% PLASTIC-FREE seals certify, in collaboration with recognised testing laboratories and accredited certification bodies, the entire product as well as either its packaging or the product itself. Products that refrain from using microplastics are transparently labelled with the PLASTIC-FREE – Product Content Microplastic-Free seal. The flustix RECYCLED trustmark certifies recyclates, semi-finished goods, and products with recycled content, including plastics, metals, and glass. flustix RECYCLABLE independently communicates the recyclability of packaging. The flustix seals serve as a guide for consumers and thereby support companies in pursuing a sustainability-focused business strategy and ensuring credible sustainability communication.

Der Beitrag EmpCo: greenwashing comes to an end – courts already rule firmly erschien zuerst auf FLUSTIX.

No inconsistent, unreliable or opportunistic politics – we need a clear course for nature, the climate, and the economy. Turning away from the Green Deal would cause far greater long-term harm than any short-term relief it may seem to offer.

Since the launch of the European Green Deal in 2019, companies worldwide have invested billions of euros in sustainable technologies, processes, and materials – and they have done so in the expectation that political conditions will remain stable. Yet our most important partner – the environment – does not pause, show leniency, or wait for human indecision. It functions reliably only if we do not disturb or hinder it.

To live up to this responsibility, we need a clear focus on three central fields of action:

• ? future-proof agriculture
• ? reliable access to raw materials as well as their responsible use and reuse
• ? and resilient, traceable supply chains.

All of this requires political consistency – not a back-and-forth between election cycles and opportunistic decisions. Businesses need planning certainty to invest boldly and purposefully in sustainable progress. Experience shows how essential this reliability is.

On 23 October 2025, the EU heads of state and government met in Brussels to once again debate whether the objectives of the European Green Deal should be weakened, and how to balance climate protection with competitiveness.
Already in November 2024, more than 50 companies – including global market leaders – had addressed an open letter to the European Commission. Their message was clear: the EU must stay on course and secure stable, long-term environmental standards. Their joint statement read:

“We, the undersigned companies, stand firmly behind the European Green Deal and its continuation.”

? Source: A business perspective: Strong environmental standards foster long-term competitiveness

Why a stable Green Deal is not only environmentally necessary but economically indispensable

Planning certainty forms the foundation for innovation and investment. When political frameworks remain stable, trust emerges along entire value chains – a crucial factor for reliable cooperation and long-term competitiveness.

Indecisive or erratic environmental policy, by contrast, generates substantial costs:

• Climate-related extreme events already cause around 143 billion USD in damages each year.
• Without effective countermeasures, losses could climb to as much as 38 trillion USD annually by 2050 – a 19% drop in global income. (Source: Nature Communications 2023 / PIK Potsdam 2024)

In addition, sudden political shifts lead to massive friction losses. Indecision creates overload, frustration, and increasing political disillusionment – all of which slow down societal and economic progress.

Signatories – strong voices from the European and global business community

Nestlé | Unilever | Ferrero | IKEA | Patagonia | Accor | Sysco | H&M Group | Danone | L’Oréal | Mars | Henkel | Ecolab | Philips | Interface | Tetra Pak | Heineken | Colgate-Palmolive | Schneider Electric | Essity | Kingfisher | Coca-Cola Europacific Partners | Saint-Gobain | Electrolux | BASF | Novozymes | Umicore | Kering | Swarovski | DHL | Vattenfall | Veolia | Iberdrola | Scania | P&G | SAP | BMW Group | Borealis | Lenzing AG | Neste | Sappi | DSM-Firmenich | Ball Corporation | ArcelorMittal | SIG Combibloc | EssilorLuxottica | Husqvarna | AB InBev | Sonae | Colruyt Group | Auchan | Carlsberg | Kärcher | Vaude | Tchibo | Wessanen | Fenix Outdoor | Sodexo | METRO AG
(Full list of signatories via the source above.)

Regulatory context at EU level

• The PPWR – Packaging & Packaging Waste Regulation – has been adopted and is now entering implementation.
• The CSRD – Corporate Sustainability Reporting Directive – remains a central instrument for transparency.
• EmpCo – Empowering Consumers for a Green Transition – is in force, protecting consumers and creating clear conditions for credible environmental communication.

In its report COM(2025) 871 final, published on 21 October 2025, the EU confirmed that the Green Claims Directive will be introduced in 2026 and will be closely linked to the Empowering Consumers Directive. According to EmpCo, a binding principle will already apply shortly:

? Every environmental and sustainability claim must be clear, verifiable, and independently substantiated.

The call to action

Politics:
We need clear, stable, and reliable rules – not policymaking that swings with shifting majorities. What matters is moving decisively in the right direction, rather than two steps forward and three steps back.

Business:
Companies must think long-term. Climate protection is not a cost factor but a fundamental basis of economic competitiveness – even when non-monetary corporate costs are not taken into account.

Society:
Success is not measured in quarters but in what holds up over the next ten or twenty-five years. If we fail to set the right course today, society will bear the costs – up to 38 trillion USD annually. When decisions are made at the top, the bill often ends up at the bottom – with the citizen.

About flustix

The organisation, founded in Berlin in 2017, offers six distinct flustix seals: The flustix LESS PLASTICS – MIN. xx% PLASTIC-FREE seals certify, in collaboration with recognised testing laboratories and accredited certification bodies, the entire product as well as either its packaging or the product itself. Products that refrain from using microplastics are transparently labelled with the PLASTIC-FREE – Product Content Microplastic-Free seal. The flustix RECYCLED trustmark certifies recyclates, semi-finished goods, and products with recycled content, including plastics, metals, and glass. flustix RECYCLABLE independently communicates the recyclability of packaging. The flustix seals serve as a guide for consumers and thereby support companies in pursuing a sustainability-focused business strategy and ensuring credible sustainability communication.

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