German (IK) /French (Elipso) Joint Opinion on the draft Commission guidance on the scope of the Single-Use Plastic Products Directive 2019/904 (as of April 2021)

We welcome the fact that the Commission is willing to adopt the guidelines, which should have been published in July 2020. Unfortunately, the current draft hardly differs from the previous draft on which we had already commented. In order to ensure a harmonised, compliant and proportionate application throughout Europe, the following aspects should be included or amended in the guidelines:

According to Article 12(1) of the Directive, only food packaging that has a "tendency to become litter, due to its volume or size, in particular single-serve portions” is covered by the Directive. We welcome the fact that the Commission - unlike in the previous version - now addresses the additional criterion for food packaging under Article 12 of the Directive. 

Link to the Joint Opinion on the draft Commission guidance on the scope of the Single-Use Plastic Products Directive