The Commission’s evaluation of the Single-Use Plastics Directive (EU) 2019/904 (SUPD)closed for stakeholder input on 17 March 2026.
Four years after the key bans and restrictions entered into force, the directive has delivered partial but insufficient progress. This post argues that the SUPD evaluation must lead to a substantially strengthened regime — one that moves beyond product bans to address the systemic drivers of plastic production, closes the enforcement gap in extended producer responsibility schemes, and confronts the growing threat of chemical additives in “bio-based” alternatives.
Background
Adopted in 2019, the SUPD banned ten categories of single-use plastic items most commonly found on European beaches and introduced extended producer responsibility (EPR) schemes for a further set of products. The directive was a landmark — the first EU legislation to directly target marine plastic litter at source. By the Commission’s own account, it was also inspired by data generated under the MSFD on the prevalence of plastic debris in EU marine waters.
What the Evidence Shows
Persistence of Plastic Litter on EU Beaches
Monitoring data from the OSPAR Commission and national marine litter programmes show that plastic items — including those theoretically banned under the SUPD — continue to appear on EU beaches in significant quantities. A 2024 study published in Marine Pollution Bulletin found that banned product categories still constituted between 12% and 18% of items collected in annual beach litter surveys across six EU member states, suggesting either non-compliance, product substitution, or legacy stock effects.
The Substitution Problem
The SUPD’s product-specific approach has driven substitution toward materials that may carry comparable or higher environmental risks. Oxo-degradable plastics, paper-based composites with plastic liners, and certified compostable polymers have all gained market share — yet their fate in the marine environment remains poorly understood. A blanket assumption that “bio-based” equals “safe for ocean disposal” is scientifically unjustified.
EPR Schemes: Under-Funded and Inconsistently Implemented
The EPR obligations under the SUPD require producers to cover the costs of awareness campaigns, litter clean-up, and waste management for their products. In practice, EPR schemes across member states vary dramatically in scope, fee structures, and enforcement capacity. Several coastal member states with the highest marine litter exposure operate EPR regimes that recover less than 40% of estimated clean-up costs from producers.
What needs to happen next
A Volume-Based Production Levy
Product bans address individual items but not the underlying problem: the EU produces approximately 55 million tonnes of plastic annually, with demand growing. The evaluation should recommend a per-kilogram levy on virgin plastic production, ring-fenced to fund marine clean-up operations and the transition to genuinely circular material flows. Several economic models — including a 2025 IEEP working paper — suggest a levy at €200–€400 per tonne of virgin plastic would generate sufficient revenue to fund national marine litter reduction plans without market distortion.
Mandatory Ocean-Fate Testing
Any substitute material claiming SUPD compliance — whether compostable, bio-based, or paper-based — should be required to demonstrate safety under marine exposure conditions, not merely industrial composting conditions. The current framework relies on end-of-life classification systems designed for terrestrial waste streams.
Harmonised Beach Litter Metrics Tied to MSFD
The SUPD evaluation data and the MSFD monitoring cycle are currently separate administrative exercises. A revised SUPD should mandate that national beach litter monitoring feeds directly into MSFD Good Environmental Status assessments, creating a single, coherent evidence base for marine plastic policy.
Upstream Legislation Through the Circular Economy Act
The SUPD is ultimately downstream legislation — it addresses the end of a linear production chain. The forthcoming Circular Economy Act must address the upstream drivers: the economic incentives for producing single-use formats in the first place.
At SAVEOCEAN we look forward to the evaluation report in July 2027. Based on the findings, it will determine whether new rules are needed. Given the evidence trajectory, a SUPD 2.0 is not a question of if but of when — and the scope of ambition of the evaluation consultation will directly shape it.
We encourage all researchers and civil society to follow the Commission’s synthesis report closely when it is published.
References
- European Commission (2025). Consultation on the Evaluation of the Single-Use Plastics Directive. DG ENV.
- Galgani, F. et al. (2024). Marine Litter Trends in European Waters 2018–2023. Marine Pollution Bulletin, 198, 115–127.
- OSPAR Commission (2024). Marine Litter Regional Action Plan: Progress Report.
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