REGULATIONS · EU SINGLE-USE PLASTICS
Are palm leaf plates allowed under the EU Single-Use Plastics Directive?
Yes. Directive (EU) 2019/904 has banned single-use plastic plates since 3 July 2021, but its definition of plastic excludes natural polymers that have not been chemically modified. A plate pressed from areca leaf, with no coating, lining or binder, is not a plastic product, so the ban, the marking rules and the plastic EPR fees do not apply to it.
For EU importers and wholesalers who need to explain to their own customers why palm leaf plates are still on the shelf.
Quick facts
- The plate ban in Article 5 of Directive 2019/904 has applied since 3 July 2021.
- Article 3(1) leaves out “natural polymers that have not been chemically modified”.
- Paper plates with a plastic lining count as single-use plastic products under the Commission’s 2021 guidelines.
- The Commission must evaluate the directive by 3 July 2027. It updated its guidelines in a notice dated 8 September 2026.
- The separate Packaging Regulation (EU) 2025/40 has applied since 12 August 2026.
What does the EU Single-Use Plastics Directive ban?
Article 5 tells every member state to stop single-use plastic products listed in Part B of the Annex from being placed on the market. The same ban covers anything made of oxo-degradable plastic. For a tableware importer, these are the lines that matter:
| Item | Rule under 2019/904 | Applies from |
|---|---|---|
| Plastic plates | Banned (Annex Part B) | 3 July 2021 |
| Plastic cutlery, including chopsticks | Banned (Annex Part B) | 3 July 2021 |
| Plastic straws and stirrers | Banned (Annex Part B) | 3 July 2021 |
| Expanded polystyrene food containers, cups and drink containers | Banned (Annex Part B) | 3 July 2021 |
| Anything made of oxo-degradable plastic | Banned (Article 5) | 3 July 2021 |
| Plastic cups for drinks | Marking required (Article 7) | 3 July 2021 |
| Areca leaf plates and bowls with no plastic layer | Outside the directive | Not applicable |
Other plastic items, such as food containers and cups, stayed on the market with consumption reduction targets and producer responsibility fees. Those rules also apply only to products that contain plastic.
Why are palm leaf plates outside the directive?
Because the directive only covers plastic, and it defines plastic narrowly. Article 3(1) says plastic is a material made of a polymer that can act as the main structural part of a product, “with the exception of natural polymers that have not been chemically modified”.
The Commission’s guidelines go further. They say cellulose and lignin from wood meet the definition of a natural polymer, and that plates made entirely of unmodified natural polymers fall outside the scope. An areca plate is the leaf sheath itself, cleaned and pressed with heat. We add no glue, no coating and no chemicals, so nothing in the plate has been chemically modified.
Are paper, bagasse and PLA plates caught by the ban?
It depends on what is in them. The 2021 guidelines state plainly that paper or board products with a plastic coating or lining are partly made of plastic. A plate made mostly of fibre but lined with plastic is therefore a single-use plastic plate, and banned.
PLA is a polymer made by chemical processing of plant starch, so a PLA plate is plastic under the directive even though it starts in a field. Bagasse is moulded fibre. A plain bagasse plate is not plastic, but some carry barrier coatings, and a buyer should ask what the coating is. If you stock a mix of materials, our palm leaf vs bagasse comparison sets out the differences.
What is changing in the 2026 and 2027 review?
Article 15 of the directive requires the Commission to evaluate it by 3 July 2027, using the data member states report under Article 13. Until that evaluation is published and any amendment goes through Parliament and Council, the 2021 rules stand as written.
The Commission did publish a notice updating its single-use plastics guidelines, dated 8 September 2026. If you sell paper, bagasse or wood items alongside palm leaf, read it in full on EUR-Lex. I would not plan stock around predictions of what the 2027 evaluation will say. Plan around the text that is in force.
How does the EU Packaging Regulation affect plates from August 2026?
The Packaging and Packaging Waste Regulation, (EU) 2025/40, is a different law. It has applied since 12 August 2026 and covers packaging, not tableware as such. A disposable plate counts as packaging when it is designed and intended to be filled at the point of sale, for example a plate a takeaway counter loads with food for the customer. A plate sold in a retail pack for use at home is generally not packaging.
Where it does apply, food-contact packaging may not contain PFAS at or above 25 ppb for any single PFAS, 250 ppb for the sum of targeted PFAS, or 50 ppm for total PFAS including polymers. There is no sell-through period for packaging first placed on the market after that date. Our plates carry no coating, so there is no grease barrier to ask about. If your plates are packaging under this rule, ask every supplier for written PFAS data, ours included.
What should an importer keep on file?
Keep a short material statement from the supplier: what the plate is made of, and that there is no coating, lining, binder or plastic layer. Add the food-contact test report and your packing list. For Germany, that report is usually an LFGB report, which our LFGB §30 and §31 page explains.
France goes further than the EU on reuse in restaurants and on green claims. If you sell there, read our loi AGEC page before you print packaging.
Questions buyers ask
Are areca leaf plates reusable or intended for single use?
They are made for single use. A plate can be wiped and used again for dry food, but we do not sell them as reusable and they are not designed for repeated washing. In law that does not matter for the SUP Directive, because it bans single-use plastic, and an areca plate is not plastic.
Do palm leaf plates need the SUP marking on the pack?
No. The Article 7 marking applies to plastic-containing products listed in Part D of the Annex, such as wet wipes, sanitary towels, tobacco filters and plastic drinks cups. Plates are not on that list, and a plate with no plastic in it is outside the directive anyway.
Is a PLA plate a plastic plate under EU law?
Yes. PLA is made by chemically processing plant starch into a polymer, so it is not an unmodified natural polymer. Under Article 3(1) of Directive 2019/904 a PLA plate is a single-use plastic plate, and the Article 5 ban applies to it from 3 July 2021.
Will the 2027 review bring palm leaf into scope?
Nobody can promise what a future amendment will say. Today the directive targets plastic, and natural polymers that have not been chemically modified are excluded by definition. Any change would need a new legislative act, which takes time, so you would have warning before it affected stock.
Do I pay single-use plastic EPR fees on palm leaf plates?
Not under the SUP Directive, whose Article 8 producer responsibility covers plastic products only. National packaging schemes are separate. If your plates count as packaging in a member state, for example when they are filled at the point of sale, you may need to register them there.
Sources
- Directive (EU) 2019/904 on the reduction of the impact of certain plastic products on the environment (EUR-Lex)
- European Commission guidelines on single-use plastic products, C(2021) 3762 final, 31 May 2021
- Commission Notice updating the single-use plastic product guidelines, 8 September 2026 (EUR-Lex)
- Regulation (EU) 2025/40 on packaging and packaging waste (EUR-Lex)
- Food Packaging Forum: PPWR PFAS limits apply from 12 August 2026
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