Eunomia Report     What is plastic …

This Eunomia report refers to the “Single Use Plastics” Directive 2019/904 which has its implementing Act scheduled 3-1-2021.

The report reflects on the fact that natural polymers could be exempted under the Directive definition of plastic, even when they have similar negative environmental effects as their “unnatural” cousins.  

The report focusses on wet wipes and the materials lycocell and viscose

Wet wipes – Stunning scale of use

The study focusses on wet wipes and states some amazing facts which include:

 7 billion wet wipes were sold in UK in 2018 with an estimated

€109 million /yr. cost of sewerage blockage removal

Wet wipes are reported to cause 93% of sewer blockages and apparently the UK are heavy users of these products.

Author aside: who can forget the  last years reports of our huge home grown fatbergs. In  February 2019 United Utilities reported the largest fatberg in the UK in a sewer at Birchall Street in Liverpool. It weighed 400 tonnes and was 250 metres long.  And in December 2019: The first occurrence of a large fatberg in the north of England was reported by United Utilities under HM Prison Manchester and this 170 ft-long monster was estimated to weigh “around the same as three elephants.”

        Flushable – To flush or not to flush

The scientific claims that  lycocell and viscose wet wipes are flushable is described as “uncertain” in this report and it should be noted that in the UK with our older sewer infrastructure a product that passes a modern flush test in a laboratory may still not be suitable for some of our older systems.”

The definition, exemption or advantage of natural materials

If the purpose is to reduce negative environmental impacts a simplistic exclusion is of concern to Eunomia which also makes reference to the ECHA non-binding definition.

The report states that any advantages regarding biodegradability and marine degradability are unclear. The environmental benefit of Man Made Cellulosic Fibres is also unclear as although it will reduce fossil fuel consumption it is estimated that 150 million trees/year are felled for the production of these fibres.

It is possible that novel biosynthesised materials may be environmentally preferable, although these will not be exempted as a natural fibre.

The substitution of plastic with other natural materials such as cotton or paper may also qualify for exemption which confer limited/unqualified environmental benefit, and concern is raised in this report regarding wet wipes and cigarette filters.

The report calls for a careful consideration of the exemption criteria to ensure that environmental benefit is achieved. 

The Full text is available at


Sign up to our newsletter and be kept up to date with announcements, news and offers.
* denotes a required field.

Get in touch

34 Milford Road
ST17 0JU

+44 (0)1785 662967
+44 (0)7801 710159

Say Hello.