Paper Technology International 2020 - Journal - Page 108

PAPERTECHNOLOGYINTERNATIONAL
The question arises: are fibre-based products concerned by
single use plastic measures at all? To evaluate that, the following
definitions are to be considered:
“Single-use plastic product” means a product that is made
wholly or partly from plastic and that is not conceived, designed or
placed on the market to accomplish, within its life span, multiple
trips or rotations by being returned to a producer for refill or re-used
for the same purpose for which it was conceived. A product that is
a single-use product by its design and its material characteristics
cannot simply be re-declared a multi-use product.
“Plastic” within the scope of the SUPD means a material
consisting of a polymer as defined in point 5 of Article 3 of the
Regulation 1907/2006 (REACH), to which additives or other
substances may have been added, and which can function as a
main structural component of final products, with the exception
plastic product; a lower threshold for a mass percentage does not
exist. Therefore, a qualitative assessment is to be applied. According
to the current interpretation, papers or board with any plastic coating
or lining are within the scope of the Directive. Illustrative examples
for different products can be found in the annex of the Commission
Guidelines [3].
Coatings or linings with natural, non-chemically modified
polymers (e.g. native starches, microfibrillated cellulose MFC,
nanocellulose, lyocell, viscose) do not contain “plastic” and won´t
be affected by the Directive. The guideline in its final version clearly
states that regenerated cellulose, e.g. in the form of a viscose,
lyocell or cellulose film, is not considered to be chemically modified.
However, polymers obtained by artificial cultivation or fermentation
processes in the industry, e.g. polyhydroxyalkanoates (PHAs)
or polylactic acid (PLA), are not considered natural polymers,
Figure 2: Examples for some products which are affected by Single-Use Plastic regulations.
of natural polymers that have not been chemically modified;
REACH defines polymer as a “substance consisting of molecules
characterised by the sequence of one or more types of monomer
units [...]”.
Single-use paper and board products that are solely
made from paper and board and do not include any plastic lining or
coating do not count as single-use plastic products for the purposes
of the SUPD. The use of synthetic polymer additives – “e.g. retention
agents, binders and processing aids” - does not transform paper
and board into a “plastic”-containing product, as the Guidelines [3]
declare.
However, “when a plastic coating or lining is applied to the
surface of a paper or board-based […] material to provide protection
against water or fat, the final product is considered a composite
product that is composed of more than one material, one of which is
made of plastics”. The Directive does not envisage any de minimis
threshold for the plastic content in a single-use product to determine
whether or not that product is covered by the definition of single-use
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because they are not the result of a polymerisation process that has
taken place in nature. Also, chemically modified natural polymers
(cellulose ethers/ esters like cellulose acetate, starch esters/ ethers
like cationic starch, or the like) are deemed to be plastics under the
regulatory framework when used for single-use products.
According to the current interpretation of the definition
of “plastic” as “polymer” according to REACH, also silicones as
coatings for paper/board are defined as plastics. This is worth
highlighting, because silicones are explicitly not regulated within
the FCM section of the “Plastics” Commission Regulation (EU) No.
10/2011 [6].
It does not matter whether the polymers used for coatings
or linings are biobased, biodegradable or recyclable in the repulping
of paper and board production – if they are considered as plastics
according to the SUPD definition, the final product will partly be
made of plastic and is therefore regulated by the Directive and
corresponding national laws.

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