Regulatory requirements, environment and waste disposal
Paper packaging is considered a sustainable alternative to plastic – but as soon as a plastic coating comes into play, the ecological balance becomes complex. The first two parts of our series examined the function of plastic layers in paper packaging (part 1) and specific plastics and alternatives (part 2). The third and final part of our series deals with the legal framework and environmental aspects that are crucial for paper-based packaging containing plastic. Particular focus is on the EU Single-Use Plastics Directive (SUPD), which has a significant impact on the use of plastic in paper products. In addition, we consider issues of recyclability, disposal and regulatory interfaces with food contact and chemicals legislation.
The Single-Use Plastics Directive (SUPD) – Significance for coated paper products
Definition and objectives
With Directive (EU) 2019/904, better known as the Single-Use Plastics Directive (SUPD), the European Union is pursuing the goal of reducing the impact of certain plastic products on the environment – especially on oceans and beaches. This applies not only to “conventional” plastic articles, but also explicitly to fibre-based products with plastic coating or lining.
This means that a paper cup with a PE or PLA coating, a coated paper plate or a takeaway cup lid made of paper with plastic film is legally considered a plastic product under the SUPD. The directive thus sets a clear framework: even small amounts of plastic can significantly change the character of a paper product – both from a regulatory and an environmental perspective.
Consequences for manufacturers and distributors
For companies, this entails considerable obligations:
- Labelling requirement: Since 2021, many paper products containing plastic must carry the “contains plastic” label (the so-called turtle symbol). This is intended to alert consumers that the product contains plastic and is not biodegradable.
- Extended producer responsibility: In future, producers will be obliged to contribute proportionally to the costs of cleaning public areas and disposing of waste from their products.
- Restrictions on use and alternative obligations: For some product categories (e. g. disposable packaging in the takeaway sector), plastic content will only be permitted to a limited extent in future – alternative materials or reusable options will be promoted politically.
The SUPD has thus had a major impact on market dynamics for paper-based packaging: the trend is towards uncoated or low-polymer papers, water-based dispersion coatings or bio-based, more easily degradable systems.
Delimitation: When is a product considered to be “plastic”?
The SUPD defines plastic as “a material consisting of a polymer to which additives or other substances have been added and which serves as the main structural component”. For paper-based packaging, this means that if the plastic layer is functional and not purely visual – i. e. if it acts as a barrier, for example – the entire packaging falls under the directive. This definition primarily applies to:
- PE, PP, PET and EVOH coatings,
- bio-based plastics such as PLA or PBS.
This creates an important incentive for innovation in the field of polymer-free coating systems.
Further regulatory references
Even though the focus is primarily on SUPD, other legal frameworks may also be relevant for coated paper products:
- Regulation (EU) No 10/2011 – regulates the use of plastics in contact with food. Plastic coatings on the food contact side must be tested for migration and may only contain approved substances. In certain cases, this can also be applied to paper/plastic composites.
- REACH Regulation (EC) No. 1907/2006 – concerns chemicals and additives in plastic coatings (e. g. plasticisers, PFAS, bonding agents). Substances of very high concern may be restricted or prohibited.
- Waste Framework Directive (2008/98/EC) – requires packaging to be designed for recycling (“design for recycling”) and the waste hierarchy (prevention > reuse > recycling > recovery) to be observed.
In practice, these regulations overlap. The SUPD defines the product category, while EU 10/2011 and REACH ensure material compliance.
Environmental aspects: Plastic coatings between function and problem
Recyclability and material separation
Plastic coatings are technically indispensable for many applications – they protect against moisture, grease and aromas and ensure sealability. However, it is precisely this functionality that causes problems in the recycling process. Paper mills can only efficiently recycle the fibre content of coated papers if the plastic content is thin, homogeneous and easily removable. Thick or complex composite structures (e. g. PE-laminated papers or multi-layer barrier composites) result in high residual material content, which must be recycled for energy.
In Germany, the so-called 5 per cent rule is often applied: if the plastic content exceeds 5 per cent of the total weight, the product may not be disposed of via waste paper recycling, but must be placed in the packaging recycling stream (“yellow bag”).
Microplastics and degradation behaviour
When coated paper ends up in the environment, the paper portion decomposes relatively quickly – but the plastic coating remains. This results in microplastic particles that are difficult or impossible to break down. Even compostable coatings (e. g. PLA or PHB) require industrial conditions with high temperatures to decompose completely. In home compost or natural environmental conditions, they usually only decompose partially.
Energy recovery and life cycle
If recycling is not technically or economically feasible, plastic components from paper composites are usually thermally recycled. Although this process generates energy, it also releases CO₂, and the material cycle remains incomplete. From an environmental point of view, materials are best when they can be recycled – i. e. returned to the recycling process. Thin, single-layer or water-soluble coating systems are particularly promising in this regard.
Conclusion
The Single-Use Plastics Directive has led to a lasting change in the packaging industry. It has made it clear that paper products containing plastic are not pure paper products.
Although plastic coatings fulfil important technical functions, they complicate recycling, impede disposal and bring manufacturers within the scope of plastics regulation. The challenge now is to maintain functional coatings without increasing the environmental impact. This can be achieved through material innovation, recycling design and early consideration of the requirements of the SUPD – because this is the only way to ensure that paper-based packaging remain legally compliant, technically feasible and ecologically sustainable in the long term.
Author: Dr. Daniel Wachtendorf, Innoform GmbH, October 2025