Single use plastic products can be manufactured from a wide range of plastics. According to the definition given in article 3 of the directive (EC) No 2019/904, ‘plastic’ means a material consisting of a polymer as defined in point 5 of Article 3 of Regulation (EC) No 1907/2006, to which additives or other substances may have been added, and which can function as a main structural components of final products with the exception of natural polymers that have not been chemically modified. The EPDLA considers a main structural component as the skeleton of an article. Without this skeleton the article will have no body nor strength.
Important applications of polymer dispersions i.e. paints (dispersion coatings), inks and adhesives are explicitly excluded from the scope of the SUPD and consequently are not considered to function as a main structural component. Also, the use of binders in certain nonwovens with natural fibers is not covered by the SUPD, as a binder can be seen in such case as a more specific form of adhesive, which is not considered to be a plastic. Furthermore, polymer dispersions, lattices and redispersible powders made thereof have contributed as a sustainable technology for many years. They may be used as raw materials in the production of plastic based materials but not as main structural components thereby falling outside of the above definition.
The EPDLA members therefore strongly advocate that polymer dispersions and redispersible powders made thereof are out of scope of this directive, when they are used as raw material for (barrier) coatings, inks, adhesives or construction materials such as screeds, plasters and mortars, as long as they do not function as a main structural component.