Commission updates single-use plastics guidelines with new cap and lid examples

The European Commission has published an updated version of its guidelines on single-use plastic products, issued as a Commission Notice in the Official Journal of the European Union on 8 September 2026. The document, published under reference C/2026/4813, updates the guidance on the interpretation and implementation of Directive (EU) 2019/904 on the reduction of the impact of certain plastic products on the environment, and is addressed to producers, national authorities and the hospitality sector.

The guidelines are issued pursuant to Article 12 of the Directive, which tasks the Commission with developing guidance, including examples of what is to be considered a single-use plastic product. They replace the previous version published in OJ C 216, 7.6.2021, p. 1, and are explicitly non-binding: the Commission stresses that the binding interpretation of EU legislation is the exclusive competence of the Court of Justice of the European Union.

A targeted update to caps, lids and covers

The Commission states that the only changes compared with the previous version concern Table 4-6 in section 4.4.2, which lists illustrative examples of different types of caps, lids and covers for single-use plastic beverage containers and cups. In particular, a new example has been added: a plastic cap used in combination with an aluminium foil lid, as found for example on bottles made of high-density polyethylene containing ultra-high-temperature (UHT) processed milk.

The update clarifies how the tethering requirement of Article 6(1) of the Directive applies to such closures. Under the new guidance:

• A plastic cap combined with an aluminium foil lid is partially included: the plastic cap is subject to the Article 6(1) tethering requirement, while the aluminium foil lid is not considered to be made of plastic pursuant to Article 6(2) and is therefore exempt.
• Metal caps or lids with plastic seals (such as roll-on pilfer-proof aluminium caps or pull-ring caps) are excluded from the tethering requirement, as they are not considered to be made of plastic.
• Plastic caps, sports caps, flip-top caps and caps on beverage pouches remain included in the scope of Article 6(1).

Definitions and scope of the Directive

The guidelines provide detailed interpretation of the key definitions in Article 3 of the Directive, including what constitutes “plastic”, a “polymer” and a “single-use plastic product”. The definition of plastic refers to the REACH Regulation (EC) No 1907/2006, and the guidance clarifies that natural polymers that have not been chemically modified fall outside the scope, while bio-based and biodegradable plastics are covered.

The document also explains the relationship between Directive (EU) 2019/904 and the Packaging and Packaging Waste Directive 94/62/EC, noting that in the event of conflict the single-use plastics Directive prevails. It covers the full list of products in the Annex, including food containers, beverage containers up to three litres, cutlery, straws, lightweight plastic carrier bags, packets and wrappers, wet wipes, balloons and tobacco products with filters.

What this means for industry and consumers

For the plastic and hospitality industries, the updated guidance provides greater legal certainty on which closures must comply with the tethering requirement and which are exempt, helping producers design compliant packaging. For consumers, the clarification reinforces the Directive’s objective of reducing the impact of single-use plastics on the environment, particularly marine litter, and of promoting the transition to a circular economy with re-usable and non-plastic alternatives.

Source: Official Journal of the European Union, C series, C/2026/4813, 8 September 2026 (official reference: C/2026/4813).