According to the signatories, the Directive, adopted in 2019, has not yet generated sufficient evidence to justify a legislative revision. They point out that several provisions are still being implemented by Member States and that reporting remains fragmented, making it difficult to assess whether the Directive is achieving its intended environmental objectives. In particular, no comprehensive data are yet available to evaluate the effectiveness of the 2026 consumption reduction targets.

The associations also highlight the uneven transposition of the SUPD across Europe. Different national approaches and instances of so-called "gold-plating" have resulted in a patchwork of regulations that increases compliance costs for companies operating across multiple Member States while weakening the integrity of the EU Single Market.

In addition, the organisations warn that revising the Directive now would create significant legal uncertainty for businesses that are still adapting to existing requirements. They argue that changing the regulatory framework during the implementation phase could delay investments and create uncertainty for manufacturers regarding future obligations and product requirements.

The joint statement further cautions against potential overlaps with other major European legislative initiatives, including the Packaging and Packaging Waste Regulation (PPWR), the Ecodesign framework and the forthcoming Circular Economy Act. According to the signatories, parallel revisions could result in conflicting or duplicative provisions, adding further complexity for industry.

The associations therefore call on EU policymakers to focus on the consistent implementation and enforcement of the existing Directive before considering any legislative revision. They argue that addressing regulatory fragmentation and ensuring harmonised application across Member States should take priority over reopening legislation that has yet to demonstrate its full impact.

The joint statement was co-signed by a broad range of European industry organisations, including EDANA, Euratex and Plastics Europe, reflecting a shared call for regulatory stability and a more coordinated approach to implementing the EU's circular economy legislation.

Joint statement on the SUPD Evaluation

The undersigned associations, representing several European industrial sectors, call on EU institutions to maintain the current legal text of the Single-Use Plastic Directive (SUPD), adopted in 2019. While the signatories recognise the importance of ensuring that the SUPD delivers measurable and meaningful environmental outcomes, reopening the Directive now will create legal uncertainty, add disproportionate burden for economic operators that are already navigating partial and often divergent national transpositions, and increase the risk of regulatory overlaps or contradictions with existing and upcoming legislation. Moreover, there is currently insufficient evidence on the effectiveness of the current SUPD to justify a revision, as described below:

• Insufficient evidence to inform a revision of the SUPD. An impact assessment of the SUPD cannot be carried out at a moment when several of its provisions are not yet in place. While a first report on the state of implementation of the SUPD was published in April 2026, it remains partial, and reporting is not harmonised, preventing meaningful comparison of data across countries. Taking the example of consumption reduction targets, Member States and other EEA countries only reported data on SUP products placed on the market in 2022 and, even for this report, did so using different indicators. Crucially, since the target on consumption reduction is set for 2026, no data are yet available on whether that target has been achieved. In summary, the partial application of the SUPD and the limited data available suggest that a revision of the SUPD would be premature at this time.

• Preventing further fragmentation and gold-plating. The transposition of the SUPD has produced significant regulatory fragmentation, uneven enforcement, and widespread instances of gold‑plating, creating persistent uncertainty for companies active across multiple Member States. The result is a patchwork of national rules that undermines the integrity of the Single Market, inflates compliance costs, and fails to deliver proportionate environmental benefits. These structural shortcomings must be fully recognised in the evaluation of the SUPD and effectively addressed prior to considering a reopening of the Directive.

• Ensuring legal certainty for economic operators. A revision of the SUPD would create legal uncertainty for companies and Member States that are still implementing several of its provisions. While the SUPD entered into force in mid-2021, the date of application for most of its provisions is at a later stage. Furthermore, the EU Commission has only recently adopted some of the implementing decisions and guidelines on the current SUPD. Any change to the SUPD at a moment when companies are still adapting to new obligations, and Member States are still in the process of implementing some key provisions, would create legal uncertainty for economic operators who do not know whether targets or the scope of the SUPD may change. Legal uncertainty carries significant economic costs for economic operators, notably in terms of investment delays likely to persist throughout the entire SUPD revision process (2–3 years).

• Avoiding overlaps with other legislation. Revising the SUPD while the Ecodesign and Packaging Regulations are still being implemented, and as negotiations on the Circular Economy Act (CEA) begin, increases the risk of regulatory overlaps and contradictions. These frameworks cover intersecting areas1 and a revision of the SUPD in parallel with the CEA would almost inevitably lead to duplicative or conflicting provisions. Even if the EU Commission ensured full coherence in its

1 It should be recalled that the SUPD is a lex specialis in relation to Regulation (EU) 2025/40 and, in case of conflict, it should prevail within the scope of its application.

proposal, the co-legislators could still introduce provisions that diverge from or contradict the SUPD framework, further undermining legal certainty and the functioning of the Single Market.

At a time when EU leaders have made regulatory simplifications and a fully integrated Single Market central to Europe’s competitiveness agenda, we urge EU policymakers to focus legislative efforts where they are most needed and avoid reopening a framework that has yet to deliver concrete results.