SUPD 2027: how much plastic can paper contain?
Europe is turning the percentage question into a market question. Diverging SUPD thresholds, PPWR requirements and national plastic taxes are making independently verified plastic content increasingly decisive for manufacturers.
A paper cup is a paper cup? Not necessarily. Products that look almost identical can be subject to different rules in Paris, Brussels or Stockholm.
What matters is a percentage you cannot see by looking at the product: how much plastic does it actually contain?
SUPD: when the zero per cent threshold becomes an implementation problem
The European Single-Use Plastics Directive (SUPD) still has no general quantitative de minimis threshold for plastic. This leaves manufacturers and authorities facing a fundamental challenge.
An absolute zero per cent threshold cannot be verified scientifically beyond doubt, and without uniform criteria authorities can hardly monitor it reliably. Every analytical method has detection limits. On top of that, synthetic polymers may be used, or may even be required, in papermaking itself. Whether these legally count as a plastic component of the final product, and how functional or non-functional polymer content should be classified, cannot be decided on the basis of a measured value alone.
Some EU member states have already responded to these practical problems.
France currently applies an eight per cent threshold to certain single-use beverage cups and has postponed its far-reaching plastic phase-out, originally planned for 2026, to 2030. Belgium relies on ten per cent, and in future eight per cent, for certain single-use products. Sweden prohibits single-use cups with a plastic content of more than 15 per cent.
Italy takes its own approach: under certain conditions, plastic coatings below ten per cent can fall outside the national definition of plastic. The Netherlands has also already adjusted its enforcement practice and applies a five per cent threshold in specific, time-limited exemptions.
Poland shows how far the uncertainty reaches: regional authorities there are documented to have reached different interpretations on comparable single-use packaging. What is assessed as permissible in one region may be classified as impermissible elsewhere.
Europe is moving towards measurable plastic content, but still without a common SUPD benchmark. The individual percentage thresholds serve different legal functions and are not interchangeable across Europe.
SUPD evaluation 2027: will the necessary harmonisation come?
The European Commission must evaluate the SUPD by 3 July 2027.
The need for action is clear: in the EU public consultation, 226 of 447 participants (50.6 per cent) reported practical difficulties with the definitions of plastic and single-use plastic products. 147 participants (32.9 per cent) explicitly described the existing definitions as unclear or inappropriate.
This is why flustix took part in the official consultation as early as March 2026 and put forward a reform proposal: an EU-wide harmonised, independently verifiable plastic threshold of no more than two per cent.
Our aim: scientifically sound criteria and verification methods, transparent controls and greater planning certainty for manufacturers and retailers.
PPWR: why the 95/5 approach sets a signal for the SUPD and is becoming economically decisive
Alongside the SUPD, the new European Packaging and Packaging Waste Regulation (PPWR) creates a further quantitative basis.
According to the European Commission’s official interpretation, paper-based packaging with a plastic content of no more than five per cent does not fall under certain PPWR bans on single-use plastic packaging that apply from 2030. This makes the 95/5 approach highly relevant for packaging developers and brand owners.
Then there is the economic dimension: more and more national rules and plans take plastic content into account in packaging levies.
A current example is the plastic packaging tax under discussion in Germany. According to the key points that have become known, certain paper-based packaging would only become taxable from a plastic content of five per cent. The rate envisaged is 550 euros per tonne of plastic.
Anyone who can prove that their product stays below a relevant plastic threshold may therefore avoid considerable levies, depending on the national tax law in question.
For manufacturers with large packaging volumes, this difference can be economically decisive. The precondition for such relief, however, is that the relevant plastic threshold can be reliably demonstrated. This is exactly where independent quantitative testing and certification become particularly important.
flustix LESS PLASTICS: one proof, several benefits
This is where flustix LESS PLASTICS – MIN. XX % PLASTIC-FREE comes in.
Independent quantitative laboratory analyses and certification document and certify the plastic content of a product or packaging in a traceable way.
Manufacturers thus gain a robust basis for regulatory assessments, product development, evidence for customers, credible environmental communication under EmpCo and potential financial benefits.
One product. One independently tested plastic content. One body of evidence for different European markets.
Why flustix deliberately relies on quantitative statements rather than blanket plastic-free promises is explained in the next section.
Why LESS PLASTICS instead of “plastic-free”? Because every per cent counts.
A paper cup can be 98 per cent paper and still not be plastic-free. The decisive difference often lies in a wafer-thin coating, a binder or other plastic components.
What sounds like a linguistic detail has long had legal consequences. As early as 2025, the German working group of food chemistry experts of the federal states (ALS) made clear that advertising certain paper cups with synthetic polymer coatings as “plastic-free” is misleading. In Denmark, too, advertising for beverage cartons that suggested they were free of plastic, although they contained plastic, was objected to.
For flustix, this is not a new topic. As early as 2017, we worked with around 50 expert and stakeholder groups on the question of how freedom from plastic can be scientifically verified and declared. As part of a DIN committee initiated in 2023, we examined the limits of absolute plastic-free claims further.
Our answer is a transparent, quantitative approach: LESS PLASTICS – MIN. XX % PLASTIC-FREE.
Instead of making an absolute zero promise, flustix documents the actual plastic content within clearly defined programme criteria. Independent laboratory testing and certification create a traceable basis for manufacturers, retailers and consumers.
With the SUPD, its increasingly divergent national plastic thresholds and the stricter EmpCo requirements, this approach is gaining in importance. After all, packaging can meet a specific statutory percentage threshold without being entirely free of plastic.
LESS PLASTICS turns a blanket statement into a reliable, independently verifiable, quantitative product property, with a licence to make the claim. More than just a promise!
Our new white paper “SUPD 2026/27, plastic content and independent evidence” shows which national criteria apply, which changes lie ahead and how companies can prepare. The white paper is available as a free download.
Sources
- Directive (EU) 2019/904 (SUPD)
- Regulation (EU) 2025/40 (PPWR)
- EU consultation on the SUPD
- ALS statement 2025/07