A broad coalition of European industry associations has called on EU institutions to maintain the current legal text of the Single-Use Plastics Directive (SUPD), warning that reopening the law at this stage would create legal uncertainty, deepen regulatory fragmentation and place an unnecessary burden on businesses already navigating uneven implementation across Member States.
In a joint appeal, the associations argued that the 2019 SUP Directive should not be revised before there is sufficient evidence to assess its environmental impact and effectiveness. They stressed that many of the Directive’s provisions are still being implemented at national level, while data on key targets—especially consumption reduction—remain incomplete and inconsistent across Europe.
Industry groups say SUPD revision would be premature
The signatory associations said that a revision of the SUPD at this stage would be premature and poorly informed, as the Directive has not yet been fully implemented and the available reporting data is too limited to support a meaningful impact assessment.
They pointed out that while the European Commission published a first report on the state of SUPD implementation in April 2026, the report remains partial and is based on non-harmonised reporting by Member States and EEA countries. In particular, countries reported 2022 data on single-use plastic products using different indicators, making it difficult to compare results or draw reliable conclusions.
The associations also noted that one of the most important benchmarks under the Directive—the 2026 consumption reduction target—has not yet been reached, meaning there is still no evidence of whether the current rules are delivering the intended environmental outcomes.
According to the industry bodies, revising the Directive before the target year has passed would undermine evidence-based policymaking and risk changing legislation before its full effects can be properly measured.
Concerns over fragmentation and national gold-plating
One of the central concerns raised by the associations is the fragmented implementation of the SUPD across the EU, with Member States transposing the rules differently and, in some cases, adding stricter national requirements beyond the original text.
The associations warned that this “patchwork” of national rules has led to uneven enforcement, gold-plating and legal ambiguity, creating major challenges for businesses operating in multiple EU markets. Instead of supporting the integrity of the Single Market, they argue, the current implementation landscape has increased compliance costs and reduced predictability for economic operators.
The signatories called on EU policymakers to first address these structural implementation issues and ensure greater harmonisation before considering any reopening of the Directive.
Legal certainty and investment stability at risk
The industry coalition also highlighted the need to preserve legal certainty for companies and Member States still adapting to the Directive’s requirements.
Although the SUPD entered into force in 2021, several of its provisions only apply at later stages, and the European Commission has only recently adopted certain implementing acts and guidelines. Businesses are therefore still in the process of adjusting systems, redesigning products, updating packaging strategies and aligning operations with national transpositions.
According to the associations, launching a revision now would create uncertainty about whether the scope, obligations or targets under the Directive may change again—discouraging investment and delaying compliance decisions.
They estimate that a full SUPD revision process could take two to three years, during which companies may postpone investments or operational changes due to lack of clarity over the final regulatory framework.
Warning against overlap with new EU sustainability laws
The signatories also cautioned against revising the SUPD at a time when several other major EU sustainability and product-policy frameworks are either being implemented or negotiated.
They pointed specifically to the rollout of the Ecodesign and Packaging Regulations, as well as the early discussions around the proposed Circular Economy Act (CEA). Revising the SUPD in parallel with these frameworks, they argue, would increase the risk of overlapping rules, conflicting obligations and duplication of regulatory requirements.
While the SUPD is considered a lex specialis in relation to Regulation (EU) 2025/40 and would prevail in case of conflict within its scope, the associations warned that co-legislators could still introduce diverging provisions through other legislative files. This could further complicate compliance and weaken the functioning of the Single Market.
Call for regulatory stability and targeted action
At a time when the EU is promoting regulatory simplification, competitiveness and a stronger Single Market, the associations urged policymakers to avoid reopening a framework that has not yet had the opportunity to fully deliver results.
Rather than revising the Directive prematurely, they called on EU institutions to focus on:
- Ensuring consistent and proportionate implementation of the existing SUPD
- Improving harmonised reporting across Member States
- Addressing gold-plating and enforcement disparities
- Avoiding overlap with packaging, ecodesign and circular economy legislation
- Allowing enough time to evaluate whether current measures achieve measurable environmental outcomes
The industry message is clear: before considering a revision of the Single-Use Plastics Directive, the EU should first allow the current framework to be fully implemented, properly measured and fairly assessed.