On December 26, 2019, law firm Keller and Heckman LLP (KH) published a summary article providing an overview of the European Commission’s (EC) initiatives related to implementing the single-use plastics directive (EU 2019/904) adopted in June 2019 (FPF reported). The directive is most well known for setting out a ban on a variety of single-use plastic products within the EU beginning in July 2021. Following its adoption, KH reports that the European Commission launched an 18-month study to inform the implementation of the directive, including a first public survey in October and November 2019. Initial results from the survey are reported to show that “many terms used in the Single-Use Plastics Directive are not well-understood, such as the difference between a ‘beverage container’ and a ‘beverage bottle,’ or what is meant by ‘packets and wrappers.’”

KH informed that a second survey has recently been announced focusing on methodologies for calculating and reporting collection targets for single-use plastic beverage bottles, tobacco product filters, single-use plastic food containers and cups, and existing practices related to litter. It is set to be open until January 10, 2020. The directive further calls for the EC to adopt a set of guidelines defining which single-use products are relevant within the directive by July 2020 and a range of implementing acts that are to be completed between July 2020 and January 2022. These acts include a methodology for calculating and verifying reduced consumption of single-use plastic products and minimum recycled content targets, formats for reporting data, and harmonized specifications for marketing. KH has further published a set of presentation slides detailing and discussing the implementation of the directive.

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KH (December 26, 2019). “EC’s Initiatives Relating to the Implementation of the Single-Use Plastics Directive.”

Rachida Semail (December 3, 2019). “The Single-Use Plastics Directive: Challenges Ahead.” (pdf) Keller and Heckman