# Single-use plastics directive by country: France adds 13 measures beyond the EU ban list, Ireland adds 1

> The single-use plastics directive by country is one EU floor plus national extras: Directive (EU) 2019/904 makes every Member State ban the same nine Part B items and all oxo-degradable plastic from 3 July 2021, and SPI counts 34 national measures beyond that list in France, Germany, Spain, Ireland, Austria, Portugal and Poland, from 13 in France to 1 in Ireland, while Poland's ban only applied from 24 May 2023.

Publisher: Strategic Packaging Insights  
Published: 2026-11-02  
Last updated: 2026-11-02  
Page: https://www.strategicpackaginginsights.com/insights/single-use-plastics-directive-by-country/

**The single-use plastics directive by country is one EU floor plus national extras: Directive (EU) 2019/904 makes every Member State ban the same nine Part B items and all oxo-degradable plastic from 3 July 2021, and SPI counts 34 national measures beyond that list in France, Germany, Spain, Ireland, Austria, Portugal and Poland, from 13 in France to 1 in Ireland, while Poland's ban only applied from 24 May 2023.**

Strategic Packaging Insights (SPI) read each country's transposing act on its official legislation site and set the extra bans, charges and reuse duties side by side with their dates. The common EU floor is narrow; the cost for a food service or packaging supplier sits in the national extras, which run from cup fees in zloty to a 2026 French cap on plastic in paper cups.

## Executive summary

The single-use plastics directive is often described as an EU ban, but it is not one law. Article 5 of Directive (EU) 2019/904 tells Member States to prohibit nine Part B products and every product made from oxo-degradable plastic, and Article 17(1) set 3 July 2021 for both the transposition and the ban (EUR-Lex). A business is bound by the national act, not the Directive, so the real ban list is national, and so are the dates and the penalties.

SPI read the transposing law in seven markets: France, Germany, Spain, Ireland, Austria, Portugal and Poland. All seven ban the Part B list. Beyond it, SPI counts 34 national measures that Article 5 does not require (Exhibit 4). France alone has 13, which is 38.2% of the total by SPI's calculation. Spain and Portugal follow with 7 each. Germany, Austria and Poland have 2 each, and Ireland has 1, its plastic bag levy.

Timing differs as much as scope. France applied most Part B bans from 1 January 2021, 183 days before the EU date, and banned plastic cups and plates in 2020. Germany and Ireland met 3 July 2021. Portugal's decree took effect on 1 November 2021, 121 days late; Spain's law was published on 9 April 2022, 280 days late; and Poland's ban applied from 24 May 2023, 690 days late, all by SPI's calculation (Exhibit 3).

Charges are the second divide. Poland makes sellers collect PLN 0.20 per plastic cup and PLN 0.25 per plastic food container from 1 January 2024. Portugal charges EUR 0.30 per single-use plastic takeaway meal pack from 1 July 2022, according to an EY tax alert. Spain requires a separate price for cups and food containers from 1 January 2023 without setting the amount, and Ireland keeps a bag levy of up to EUR 0.22 (Exhibit 7).

The Commission has written to three Member States about the quality of their transposition in 2025, including Germany and Poland, and must evaluate the Directive by 3 July 2027. From 1 January 2030 the PPWR's Annex V format bans and its extruded polystyrene ban add an EU-wide layer that applies without transposition.

For leaders, the work is to map every SKU and service format against seven lists, not one, and to price the cup and container charges into 2027 plans. This is business guidance, not legal advice.

## Key findings

1. All seven markets ban the nine Part B items and oxo-degradable plastic, but SPI counts 34 national measures beyond that list: France 13, Spain 7, Portugal 7, Germany 2, Austria 2, Poland 2 and Ireland 1 (SPI analysis, Exhibit 4).
2. France applied most Part B bans from 1 January 2021 and will allow only traces of plastic in partly plastic cups from 1 January 2026, the strictest cup rule of the seven (Ministère de la Transition écologique, updated 4 February 2026).
3. **SPI calculation:**  against the EU date of 3 July 2021, Portugal's Decreto-Lei 78/2021 took effect 121 days late, Spain's Ley 7/2022 was published 280 days late and Poland's ban applied 690 days late.
4. Portugal set the deepest numeric cut for cups and food containers of the seven: 80% by 31 December 2026 and 90% by 31 December 2030, against 2022, measured by plastic mass (Decreto-Lei 78/2021, Article 5). Spain set 50% and 70% for the same dates.
5. Point-of-sale charges run in two currencies: PLN 0.20 per cup and PLN 0.25 per food container in Poland from 1 January 2024 (Dz.U. 2023 poz. 2679), and EUR 0.30 per plastic takeaway meal pack in Portugal from 1 July 2022 (Portaria n.º 331-E/2021; amount as reported by EY, not yet confirmed by SPI in the Portaria text).
6. Only Ireland and Germany state a penalty ceiling in the texts SPI read: up to EUR 500,000 or three years on indictment in Ireland (S.I. No. 326 of 2021, regulation 7), and up to EUR 100,000 as an administrative fine in Germany (section 4 EWKVerbotsV with section 69 KrWG).

## What the EU single-use plastics ban list covers

Article 5 is one sentence. It reads in full: "Member States shall prohibit the placing on the market of the single-use plastic products listed in Part B of the Annex and of products made from oxo-degradable plastic." The SPI rule note for [PR-EU-014](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-014/) records that the Directive rests on Article 192(1) TFEU, the environment legal basis, which is why it binds businesses only through national law.

The list is narrow by design. The Directive treats cups and food containers made of other plastics as Part A items under Article 4, where Member States must achieve a measurable quantitative reduction in consumption by 2026 compared with 2022, and may restrict them on the market by derogation from the old packaging directive (EUR-Lex). That is the door through which several of the seven countries walked to add charges and targets.

The Commission's guidelines of 7 June 2021, as summarised in the [PR-EU-014](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-014/) rule note, set the tests that national lists then borrow. A paper plate with a plastic lining is a plastic plate. Polymers made by fermentation, such as PHA, and chemically modified ones, such as cellulose acetate, count as plastic, so a bio-based fork is usually banned. Binders used only as processing aids do not make a paper straw plastic, but a coating does.

SPI analysis

The guidelines are why the same paper cup can be lawful in Dublin and restricted in Paris. Ireland applies the EU tests and stops there; France applies them and then adds a national ceiling on plastic content in cups (Exhibit 5).

## Seven markets, seven start dates

The Directive set one date. The seven national acts arrived across almost three years (Exhibit 3).

**France**  started first. Article 77 of the AGEC law, loi n° 2020-105 of 10 February 2020, set 1 January 2020 for disposable plastic cups, glasses and plates sold in lots, and 1 January 2021 for straws, cutlery, stirrers, cup lids, steak picks, balloon sticks, confetti and expanded polystyrene food and drink containers (Légifrance).

**Germany**  made a dedicated ordinance. Section 3(1) of the EWKVerbotsV bans the nine Part B items, section 3(2) bans products made from oxo-degradable plastic, and section 5 puts the ordinance into force on 3 July 2021 (gesetze-im-internet.de). **Ireland**  made S.I. No. 326 of 2021 on 2 July 2021, with its regulation 4 ban taking effect the next day; the government page, updated on 27 January 2026, now names S.I. No. 516 of 2021, as amended by S.I. No. 136 of 2022, as the transposing act.

**Austria**  placed the ban in sections 13n and 13o of the Waste Management Act, the AWG 2002 (BMLUK). The chamber of commerce in Lower Austria told members on 11 March 2023 that the ban applied from 3 July 2021, and that products already bought in Austria could still be sold while goods imported only for resale could not. SPI has not yet confirmed from RIS the date the AWG amendment first applied; an unofficial consolidation shows the current section 13n in force since 11 December 2021.

**Portugal**  transposed through Decreto-Lei n.º 78/2021 of 24 September 2021, whose article 4 bans the Part B list and oxo-degradable products and whose article 30 brings it into force on 1 November 2021 (Diário da República).

**Spain**  put the ban in Article 56 of Ley 7/2022, published in the BOE on 9 April 2022. MITECO's page lists the Part B items, oxo-degradable plastic and intentionally added plastic microspheres under 5 mm as prohibited under Article 56.

**Poland**  came last. The ministry says the act of 14 April 2023 amending the act on business obligations for certain waste and the product fee banned the Part B items and oxo-degradable products from 24 May 2023 (gov.pl).

## Single-use plastics directive by country: what each market bans beyond Article 5

Exhibit 4 is the core of this piece. SPI counted a measure where a national act bans a product, requires a charge at the point of sale, or requires a reuse option or loose sale, beyond what Article 5 requires. EU-wide duties that every Member State must apply, such as tethered caps and marking, are left out, and so are numeric reduction targets, which are in Exhibit 6.

SPI analysis

The 34 measures fall into three groups. Fourteen are product bans, almost all in France; ten are reuse or loose-sale duties; and the rest are charges, bag rules or event duties. Germany, Austria, Ireland and Poland added little to the product list itself. Their extra measures sit around carrier bags, reuse and cup charges, which is where the Part A consumption target pushes.

Three dates in the exhibit need care. France's fruit and vegetable rule is in force, but the SPI France record notes that AIDA lists Décret n° 2023-478, which set the list of exempt produce, as abrogated after a Conseil d'État decision of 8 November 2024; the ministry page still cites it. Spain's loose-sale duty depends on a Ministry of Agriculture order listing exempt produce, which Real Decreto 1055/2022 required within six months; SPI has not yet confirmed that the order has been adopted. Germany's reusable offer moved from the Verpackungsgesetz into section 60 of the VerpackDG of 13 July 2026, and SPI has not yet confirmed its first start date against the archived text.

## France: the longest national list

France's list is long because it started before the Directive and kept going after it. The SPI rule note for [PR-FR-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/france/pr-fr-002/) places most bans in article L. 541-15-10 of the Code de l'environnement, with product definitions in article D. 541-330, and links them to the 2015 energy transition law that removed plastic checkout bags in 2016 and 2017.

The cup ceiling shows how France goes further on a Part A item. The ministry page, updated on 4 February 2026, says partly plastic cups were allowed above 15% plastic only until 1 January 2022, then 8% from 1 January 2024, and traces only from 1 January 2026. The same page says a cup with no plastic at all is not technically feasible before 2030, which means the 2026 step turns on the meaning of traces.

In SPI analysis, most French bans bite on the business that sells or hands out the item, which places the compliance work on retail, catering and brand owners rather than converters. The SPI Ledger piece on [France's AGEC law and Triman](https://www.strategicpackaginginsights.com/insights/france-agec-triman-packaging/) covers the 3R targets and the 2040 goal, which this piece does not repeat.

## Germany, Ireland and Austria: the EU list plus bags and reuse

The three markets with the shortest national lists share a pattern: they copied Part B closely, then regulated around carrier bags and reuse.

**Germany.**  Section 12(1) of the VerpackDG bars final distributors from supplying lightweight plastic carrier bags intended to be filled at the point of sale, and exempts very lightweight bags needed for hygiene or offered as packaging for loose food to prevent food waste (gesetze-im-internet.de). The rule began on 1 January 2022 under section 5(2) of the Verpackungsgesetz, covering bags of 15 to 50 microns, according to the chamber of commerce in Hanau. Section 12(2) keeps the EWKVerbotsV restrictions in place. Section 60 requires takeaway sellers to offer reusable packaging at no higher price, which the SPI Ledger piece on [German packaging law](https://www.strategicpackaginginsights.com/insights/germany-packaging-law-2026-verpackg-plastic-tax/) sets out in full.

Germany's largest extra is not a ban. The single-use plastics fund charges producers of to-go containers, cups, bags and other items the Directive does not ban, and the SPI rule note for [PR-EU-014](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-014/) stresses that the ban and the levy apply to different product lists. The SPI Ledger piece on the [Einwegkunststofffonds](https://www.strategicpackaginginsights.com/insights/germany-single-use-plastic-fund-levy-items/) prices that levy item by item.

**Ireland.**  S.I. No. 326 of 2021 bans the Part B list and every product made wholly or partly of oxo-degradable plastic, with the Environmental Protection Agency named as the enforcement authority (Irish Statute Book). Its one national extra in SPI's count is older than the Directive: the plastic bag levy, which began at 15 cent on 4 March 2002 and rose to 22 cent on 1 July 2007, according to Galway County Council.

**Austria.**  The federal business service portal, updated on 1 January 2026, says plastic carrier bags have been banned since 1 January 2020 under sections 13j to 13m of the AWG 2002, with exemptions for very light biodegradable fruit and knot bags up to 15 microns and for reusable woven bags. Section 14b, as consolidated by gesetzefinden.at, requires grocery retailers to offer reusable drinks in at least 35% of stores over 400 m2 from 1 January 2024 and 90% from 1 January 2025, with all such stores covered by the end of 2025.

## Spain and Portugal: bans, charges and targets together

Spain and Portugal took a different route. They added fewer national product bans than France but combined them with charges, numeric targets and reuse duties.

**Spain.**  Article 55 of Ley 7/2022 requires, from 1 January 2023, a price for each Part A product handed to consumers, shown separately on the receipt, and sets reductions by weight of 50% by 2026 and 70% by 2030 against 2022 (MITECO). Real Decreto 293/2018 had already banned free plastic bags from 1 July 2018, fragmentable bags from 1 January 2020 and lightweight and very lightweight bags unless compostable from 1 January 2021 (BOE). Article 7 of Real Decreto 1055/2022 adds loose sale of fresh produce, a 20% unpackaged sales area for food stores of 400 m2 or more, free unpackaged water in hospitality and, from 1 July 2023, a duty on event organisers to replace single-use bottles and cups (BOE).

**Portugal.**  Decreto-Lei 78/2021 sets the deepest cut of the seven: cups and food containers must fall 80% by 31 December 2026 and 90% by 31 December 2030 against 2022, by plastic mass, with the Agência Portuguesa do Ambiente (APA) and the consumer affairs directorate due to assess new measures by 31 December 2025 (article 5). Its article 6 requires, from 1 January 2024, a reusable option for takeaway and delivery at no worse terms, own-container use in new vending machines and reusable utensils for dine-in. Two 2019 laws add a ban on single-use plastic tableware in food service and retail and, from 1 June 2023, a ban on very light plastic bags and plastic containers for bakery, fruit and vegetables.

SPI analysis

Portugal's 80% target falls due on 31 December 2026, 59 days after this piece is published by SPI's calculation. SPI has not yet confirmed any official measurement of progress against it, so a business selling takeaway food in Portugal should plan for article 5(6), which lets the government adopt new measures, such as restrictions on sales, if the target is missed.

## Charges at the till, in each currency

Four of the seven markets put a price on single-use items at the point of sale. Each charge is shown in its own currency, and SPI does not compare them across currencies.

Poland's regulation of 7 December 2023 fixes PLN 0.20 for beverage cups, including lids, and PLN 0.25 for food containers for food that is ready to eat, eaten on site or taken away, and enters into force on 1 January 2024 (ISAP). Within Poland's own currency, a container costs 1.25 times a cup, by SPI's calculation.

Portugal's contribution applies to plastic or plastic-multimaterial packs from 1 July 2022 and to aluminium packs from 1 January 2023, under article 320 of the 2021 State Budget Law and Portaria n.º 331-E/2021 (APA). The EY tax alert of 12 July 2022 gives the amount as EUR 0.30 per pack for meals bought for takeaway, drive-in or home delivery.

SPI analysis

These are price signals to the customer, not producer fees. They change what the customer pays at the till and, through that, how many single-use packs a food service brand orders. That is a different lever from EPR fees, which the SPI Ledger piece on [EPR fees per tonne](https://www.strategicpackaginginsights.com/insights/epr-fees-per-tonne-2026/) compares across schemes.

## A framework: four national strategies

SPI groups the seven markets by two questions: how far does the national product ban list go beyond Part B, and how hard does the state push on Part A cups and containers through targets, charges or reuse duties (Exhibit 8).

The framework is a planning device. A packaging buyer in a list-builder market needs a dated item register; in a price-and-target market, a forecast of unit volumes against the target; in a reuse-around-the-edges market, an operating model for reusable cups and containers; and in a copy-out market, a watch on EU law, because that is where the next change will come from.

In practice: McDonald's.

The SPI [Buyers Database](https://www.strategicpackaginginsights.com/data/packaging-buyers-database/) records 1,630 restaurants in France and 1,382 in Germany, and the two sit in different strategies. In France, the record notes that reusable tableware is already required for dine-in meals and that [PR-FR-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/france/pr-fr-002/) removed disposable cutlery, stirrers and cup lids from 1 January 2021. In Germany, the same chain's takeaway containers and cups pay the single-use plastics fund levy, and reusable cups and lids carry a EUR 2 deposit. The same menu therefore meets a ban in one market and a levy plus a reuse offer in the other.

In practice: Germany's single-use plastics fund.

The SPI Germany note records that producers of listed single-use plastic products pay into a federal fund run by the Umweltbundesamt through its DIVID platform, which it expected to serve about 56,000 levy payers. That fund is Germany's main answer to the Part A items and is one reason Germany's national ban list is short: the country prices to-go packaging rather than banning it.

## Penalties and enforcement

Article 14 of the Directive leaves penalties to Member States, which must make them effective, proportionate and dissuasive and notify them to the Commission by 3 July 2021 (EUR-Lex). The texts SPI read state a ceiling in two of the seven markets.

Portugal's decree is the clearest on who acts. Article 17 makes breaches of the article 4 ban and of the article 6 reuse duty serious economic offences, enforced by ASAE, while environmental offences go to IGAMAOT, with the tax authority and police also holding powers (Decreto-Lei 78/2021, articles 16 to 19). Germany's section 4 EWKVerbotsV makes it an administrative offence to place a banned product on the market, whether intentionally or negligently, under section 69(1) number 8 of the KrWG.

At EU level, enforcement runs through infringement cases on transposition rather than on shops. In 2025 the Commission sent letters of formal notice on Directive (EU) 2019/904 to Poland in June and to Germany and Estonia in July. SPI has not yet confirmed any later step in the Polish or German cases.

## Scenarios: what the cup and container charges move

The charges in Exhibit 7 are collected from customers, so they work on demand. SPI modelled one hypothetical takeaway operator handing out 100,000 single-use plastic food containers a year in Portugal and the same number in Poland, plus 100,000 cups in Poland, under three switch rates to reusable or non-plastic packs. The 80% switch matches Portugal's 2026 target; 50% is a midpoint; 0% means no change.

SPI analysis

The money matters less than the signal. In both markets the fee is visible to the customer, so the commercial question is whether the reusable route, which Portugal's article 6 says may not cost the customer more, wins the order at the counter. Operators with high takeaway volumes in Portugal also face the 80% target date at the end of 2026, which could bring sales restrictions if missed.

## How the PPWR changes the picture from 2030

The national lists are not the end of the story. The SPI rule note for [PR-EU-014](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-014/) records that the PPWR's Annex V format bans apply from 1 January 2030 and prevail over the Directive for those formats, while anything not in Annex V stays under the Directive, so the two lists must be read together (Commission Notice C/2026/3084, section 16). Article 67(5) of Regulation (EU) 2025/40 adds extruded polystyrene food containers, beverage containers and cups to the polystyrene ban from the same date, with no transposition needed.

The [PR-FR-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/france/pr-fr-002/) note adds that the PPWR restricts plastic packs for produce lots under 1.5 kg and packaging for food eaten on site from 2030, the same thresholds France chose in 2022 and 2023. In SPI analysis, that will turn parts of the French, Spanish and Portuguese lists into an EU-wide floor and make them partly duplicative. The SPI Ledger piece on [PPWR 2030 format restrictions](https://www.strategicpackaginginsights.com/insights/ppwr-2030-format-restrictions/) sets out Annex V format by format.

Before then, the Commission must evaluate the Directive by 3 July 2027 under Article 15, 243 days from publication of this piece by SPI's calculation. The [PR-EU-014](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-014/) note records that the review will cover coherence with the PPWR and that a legislative proposal could follow. The SPI Ledger piece on [tethered caps](https://www.strategicpackaginginsights.com/insights/tethered-caps-two-years-single-use-plastics-directive/) covers the Article 6 side of that evaluation.

## Industry reaction

> "Germany has not correctly transposed several provisions of the Single-Use Plastic Directive."

***European Commission** , [July 2025 infringements package: key decisions](https://malta.representation.ec.europa.eu/news/july-infringements-package-key-decisions-2025-07-17_en), 17 July 2025*

The Commission's points concerned undefined terms that make producer cost calculations unclear, gaps in rules on separate collection, and the absence of an awareness campaign on reusable alternatives and littering. They did not concern the Part B ban list itself.

> "Therefore, the scope of the application of the rules on single-use plastic is limited."

***European Commission** , on Poland, [June 2025 infringements package: key decisions](https://malta.representation.ec.europa.eu/news/june-infringements-package-key-decisions-2025-06-18_en), 18 June 2025*

The same item says Poland's law does not ensure that waste management costs under producer responsibility schemes are properly calculated and borne. Poland had two months to reply.

> "Single use plastic items are used once, or for only a short period of time, before being thrown away."

***Department of Climate, Energy and the Environment, Ireland** , [Single use plastics](https://www.gov.ie/en/department-of-climate-energy-and-the-environment/publications/single-use-plastics/), updated 27 January 2026*

The page lists Ireland's bans since 3 July 2021, tethered caps since 3 July 2024 and a public drinking water scheme with EUR 2 million from the Circular Economy Fund, which is funded in part by the plastic bag levy.

## What leaders should do now

1. **Packaging and compliance leads, by 31 December 2026:**  build one item register with a column per market, using Exhibit 4, and record polymer, coating and lining for every cup, plate, container, straw and cutlery SKU against the Commission's 2021 tests.
2. **Food service operations in Portugal, by 31 December 2026:**  measure 2026 plastic cup and container volumes against the 2022 base, because article 5 sets an 80% cut by that date and allows new sales restrictions if it is missed.
3. **Procurement teams supplying France, now:**  obtain written plastic content figures for every partly plastic cup, because only traces are allowed from 1 January 2026.
4. **Finance teams in Poland and Portugal, by the 2027 budget:**  price the PLN 0.20 and PLN 0.25 fees and the EUR 0.30 contribution into menu prices and reuse business cases, each in its own currency.
5. **Takeaway operators in Germany, Austria and Portugal, now:**  check that the reusable offer, signage and own-container options required by VerpackDG section 60, AWG section 14b and Decreto-Lei 78/2021 article 6 are live in every site.
6. **Regulatory affairs, by 3 July 2027:**  prepare evidence for the Commission's evaluation, including sales and return data on reusable alternatives, and map which national bans the PPWR will absorb from 1 January 2030.
7. **Legal teams, before any new market entry:**  confirm the penalty and enforcement provisions marked "not confirmed" in Exhibit 9 with counsel in each market.

## Questions for your board

- In how many of our seven markets do we sell an item that is lawful in one and banned in another?
- Do we know the plastic content of every paper cup we buy for France?
- What share of our Portuguese takeaway volume is still single-use plastic, and what would a sales restriction after 2026 cost?
- Are the cup and container charges in Poland and Portugal changing customer choice at our counters?
- Which of our reuse pilots could become the evidence the Commission asks for in its 2027 evaluation?
- Which national rules will the PPWR replace in 2030, and which will remain on top of it?

## What to watch

- **31 Dec 2026:**  Portugal's 80% and Spain's 50% reduction targets for cups and food containers fall due, against 2022.
- **2027:**  Commission decisions on the open infringement cases against Poland and Germany; SPI has not yet confirmed a date.
- **3 Jul 2027:**  Commission evaluation of Directive (EU) 2019/904 due under Article 15.
- **1 Jan 2028:**  France's catering container rule reaches communes under 2,000 inhabitants.
- **1 Jan 2030:**  PPWR Annex V format bans and the extruded polystyrene ban apply; Portugal's 90% and Spain's 70% targets fall due.

## Methodology

- **Data used:**  Directive (EU) 2019/904 on EUR-Lex; SPI rule notes [PR-EU-014](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/european-union/pr-eu-014/) and [PR-FR-002](https://www.strategicpackaginginsights.com/data/packaging-regulation-tracker/france/pr-fr-002/) and jurisdiction files FR, DE, ES, IE, AT, PT and PL (data as of 14 October 2026); national acts on Légifrance, gesetze-im-internet.de, BOE, the Irish Statute Book, ISAP, and copies of Diário da República texts; ministry and regulator pages in each market; Commission infringement summaries for 2025; consulted 14 October to 2 November 2026.
- **Counting rule:**  a measure counts in Exhibit 4 where a national act bans a product, requires a point-of-sale charge, or requires a reuse option or loose sale, beyond Article 5. EU-wide duties under Articles 6 to 10 and numeric reduction targets are excluded. Where one article sets several dated items, SPI counts each item a business must act on separately.
- **Unofficial texts:**  Austria's AWG sections 13n and 14b were read from gesetzefinden.at, an unofficial consolidation, and are not yet confirmed against RIS. Decreto-Lei 78/2021 was read from a copy of the Diário da República text hosted by Sociedade Ponto Verde. Portugal's EUR 0.30 amount comes from an EY tax alert and is not yet confirmed from the Portaria text.
- **Calculations:**  day counts run from 3 July 2021 for transposition and from 2 November 2026 for deadlines. Scenarios use statutory per-item charges and SPI's assumed volumes, in one currency at a time, with no conversion.
- **Limitations:**  SPI has not yet confirmed penalty amounts for France, Spain, Austria and Poland, the first start date of Germany's reusable offer, Spain's Article 56 start date and loose-sale exemption order, or Ireland's position on a disposable cup levy. This is analysis, not legal advice; check edge cases with counsel.

## Sources

1. EUR-Lex, Directive (EU) 2019/904, OJ L 155, 12.6.2019 (Articles 4, 5, 14, 15, 17; Annex Parts A and B), [https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L0904](https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32019L0904), consulted 2026-11-02.
2. European Commission, June 2025 infringements package (Poland), [https://malta.representation.ec.europa.eu/news/june-infringements-package-key-decisions-2025-06-18_en](https://malta.representation.ec.europa.eu/news/june-infringements-package-key-decisions-2025-06-18_en), consulted 2026-11-02.
3. European Commission, July 2025 infringements package (Germany and Estonia), [https://malta.representation.ec.europa.eu/news/july-infringements-package-key-decisions-2025-07-17_en](https://malta.representation.ec.europa.eu/news/july-infringements-package-key-decisions-2025-07-17_en), consulted 2026-11-02.
4. Légifrance, Loi n° 2020-105 du 10 février 2020, article 77, [https://www.legifrance.gouv.fr/loda/article_lc/JORFARTI000041553842](https://www.legifrance.gouv.fr/loda/article_lc/JORFARTI000041553842), consulted 2026-11-02.
5. Ministère de la Transition écologique, Lutte contre la pollution plastique (updated 4 February 2026), [https://www.ecologie.gouv.fr/politiques-publiques/lutte-contre-pollution-plastique](https://www.ecologie.gouv.fr/politiques-publiques/lutte-contre-pollution-plastique), consulted 2026-11-02.
6. gesetze-im-internet.de, Einwegkunststoffverbotsverordnung, sections 3 to 5, [https://www.gesetze-im-internet.de/ewkverbotsv/](https://www.gesetze-im-internet.de/ewkverbotsv/), consulted 2026-11-02.
7. gesetze-im-internet.de, VerpackDG, section 12, [https://www.gesetze-im-internet.de/verpackdg/__12.html](https://www.gesetze-im-internet.de/verpackdg/__12.html), consulted 2026-11-02.
8. IHK Hanau, Plastiktütenverbot, [https://www.ihk.de/hanau/nachhaltigkeit-und-digitalisierung/umwelt/plastiktuetenverbot-6552422](https://www.ihk.de/hanau/nachhaltigkeit-und-digitalisierung/umwelt/plastiktuetenverbot-6552422), consulted 2026-11-02.
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