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Single-use plastic marking: what Article 7 actually requires on pack
Status
Mandatory in the EU and EEA for the four product families listed in Part D of the Annex to Directive (EU) 2019/904. Article 7(1) has applied from 3 July 2021. Harmonised artwork is fixed by Commission Implementing Regulation (EU) 2020/2151, also applying from that date. This is legislation, not a scheme. Fishing gear is not an Article 7 marking product.
Marks and reference graphics are shown for identification, academic research and commentary. The image does not grant permission to apply a scheme mark to packaging; consult the issuing body's current eligibility and artwork rules. Licensed marks are not reconstructed as production files.
The mark, and what it is not
The Single-Use Plastics Directive does two different things on pack, and they are often collapsed. Article 5 bans listed single-use items and products made from oxo-degradable plastic. Article 7 does not ban anything. It requires a mark on four product families only: certain sanitary items, wet wipes, tobacco filters, and beverage cups.
The product list is closed. Part D names four families only: sanitary towels (pads), tampons and tampon applicators; wet wipes, that is pre-wetted personal care and domestic wipes; tobacco products with filters and filters marketed for use with tobacco products; and cups for beverages (Directive (EU) 2019/904, Annex, Part D). Cutlery, plates, straws, balloon sticks and expanded-polystyrene food containers sit in other parts of the Annex and are subject to restriction or consumption-reduction duties, not to this marking. Fishing gear containing plastic is already subject to marking under Council Regulation (EC) No 1224/2009; Recital 20 of the Directive records that fact, and fishing gear does not appear in Part D. An “SUP mark” on a fishing net, a plate or a bottle is not an Article 7 mark.
The Commission was required to adopt harmonised specifications by 3 July 2020. It did so in Implementing Regulation (EU) 2020/2151 of 17 December 2020, which applies from 3 July 2021 — the same day as Article 7(1). The implementing act, not the Directive, is the artwork specification. It also states that the design shall be reproduced “without adding any effects, adjusting the colours, retouching or extending the background” (IR (EU) 2020/2151). Redrawing the pictogram for a brand guideline is a non-conformity, not a localisation.
Where it prints, and the millimetre table
The Directive itself allocates the marking between packaging and product. For the sanitary, wipe and tobacco families, the implementing act must provide that the marking is placed on the sales and grouped packaging, that each sales unit bears a marking where multiple units are grouped at the point of purchase, and that “the marking shall not be required for packaging with a surface area of less than 10 cm²” (Directive (EU) 2019/904, Art. 7(2)(a)). For beverage cups, the marking “shall be placed on the product itself” (Art. 7(2)(b)). Those are statutory placement rules, not scheme preferences.
The implementing regulation then fills in the printer-facing numbers. For sanitary items, wet wipes and tobacco packaging the printed marking is to sit on a named external face (front or top for most packs; the back of a tobacco unit packet, without obstructing health warnings required by Directive 2014/40/EU). Size is specified as a 1:2 rectangle: a minimum of 1.4 cm by 2.8 cm (3.92 cm²) where the relevant surface is less than 65 cm²; at least 6 per cent of the surface otherwise; and a maximum of 3 cm by 6 cm (18 cm²). Printed resolution is specified at a minimum of 300 dpi, type as Helvetica Bold, and the colour set as white, black, red and blue with named CMYK values, bordered by a thin white line (IR (EU) 2020/2151, Annexes I–III).
Cups are treated separately because the marking is on the drinking vessel. For traditional cups it sits on the external surface away from the rim, so that it does not contact the mouth; it is not placed under the base. Champagne-type cups may use the upper side of the base. Size is keyed to capacity: a minimum of 1.4 cm by 2.8 cm below 500 ml, and 1.6 cm by 3.2 cm at 500 ml and above. Cups made wholly of plastic may be printed or engraved/embossed; the engraved/embossed variant uses the wording “MADE OF PLASTIC” (IR (EU) 2020/2151, Annex IV). A time-limited sticker derogation ran until 4 July 2022 and has expired.
| Field | Rule |
|---|---|
| Bound party | The person placing a Part D product on the market in a Member State. Member States had to transpose Article 7 by 3 July 2021 (Art. 17). |
| In-scope products | Only Annex Part D: sanitary towels, tampons and applicators; wet wipes; tobacco products with filters and such filters; beverage cups. Not fishing gear. Not the Article 5 banned items. |
| Mark | The harmonised pictogram in the annexes to IR 2020/2151, plus the information text in the official language or languages of the Member State. Do not redraw. |
| Size / colour / placement | IR annexes: 1.4 × 2.8 cm minimum (surface < 65 cm²) or ≥ 6 per cent of the surface, capped at 3 × 6 cm. Cups: 1.4 × 2.8 cm below 500 ml; 1.6 × 3.2 cm at or above. Named CMYK. Cups on the product, away from the rim. |
| Digital substitute | None. The marking is physical. The 10 cm² rule is an exemption, not a QR opt-out. |
| Exemptions | Packaging with a surface area of less than 10 cm² (Art. 7(2)(a)). Products not listed in Part D. |
| In force | 3 July 2021. Sticker derogation ended 4 July 2022. |
| Do not | Put the mark on plates, straws, bottles or fishing gear and call it Article 7. Print it on cup packaging instead of the cup. Reconstruct the pictogram. Treat it as a recycling or compostability instruction. |
What the proposition is
The recitals state the information failure the mark is meant to close. Certain single-use plastic products “end up in the environment as a result of inappropriate disposal through the sewer system or other inappropriate release”; there is “frequently a significant lack of information about the material characteristics of the product or the appropriate means of waste disposal”; and the marking should tell the consumer both how not to dispose of the item and that it contains plastic (Directive (EU) 2019/904, recitals on marking). The mark is therefore a harm-and-disposal notice, not a recyclability claim, not a recycled-content claim, and not a sorting instruction of the How2Recycle / OPRL / Info-tri kind. “PLASTIC IN PRODUCT” is an identity statement. It does not say where the item goes in a municipal system.
Two neighbouring duties are easy to confuse with it. Article 10 requires Member States to take awareness-raising measures about reusable alternatives, waste-management options and the impact of littering; producers cover those costs under Article 8 extended producer responsibility. Those are information campaigns, not on-pack marks. Tobacco marking under Article 7 is “in addition to” the health warnings in Directive 2014/40/EU (Art. 7(3)) — it does not replace them, and the implementing regulation forbids the SUP mark from covering them.
Traps
The most common misreading is scope. “Single-use plastic” in public debate names a Directive; on pack it names four product families. A drinks bottle is a single-use plastic product for other articles of the Directive (tethered caps, recycled-content targets) and is not an Article 7 marking product. A wet wipe is. A cup is marked on the cup; a wipe is marked on the pack. The 10 cm² figure is a packaging-surface exemption in the Directive, not a general small-item opt-out, and it does not authorise a digital substitute of the French 10/20 cm² kind documented in the France report.
The second trap is artwork. Because the pictogram is in the Official Journal annexes, brand teams are tempted to redraw it at the brand’s line weight or in a single spot colour. The implementing regulation forbids adding effects, adjusting colours or retouching. The millimetre table is in the instrument; it is not a scheme kit. This atlas does not supply a production file.
The third is legal character. Article 7 is a Member State duty implemented by national transposition, backed by an EU implementing regulation that is directly applicable. It is not a TÜV, BPI or How2Recycle licence, and it is not the forthcoming PPWR harmonised composition label under Regulation (EU) 2025/40 Article 12, which is a different mark on a different timetable, treated in the PPWR on-pack article.
References
Directive (EU) 2019/904 of the European Parliament and of the Council of 5 June 2019 on the reduction of the impact of certain plastic products on the environment. OJ L 155, 12.6.2019.. Available at: Open source (Accessed: 22 August 2026).
Commission Implementing Regulation (EU) 2020/2151 of 17 December 2020 laying down rules on harmonised marking specifications on single-use plastic products listed in Part D of the Annex to Directive (EU) 2019/904. OJ L 428, 18.12.2020.. Available at: Open source (Accessed: 22 August 2026).
European Commission (n.d.) Single-use plastics.. Available at: Open source (Accessed: 22 August 2026).
Note on sources and verification
Article 7, Article 7(2)(a)–(b), Article 17 application dates, Annex Part D and Recital 20 are quoted or closely paraphrased from the EUR-Lex HTML of Directive (EU) 2019/904. Placement, millimetre bands, cup-on-product rules, colour values, the expired sticker derogation, the “do not redraw” design rule and the prescribed information texts are taken from the EUR-Lex HTML of Implementing Regulation (EU) 2020/2151 and its annexes. Millimetre figures appear only because the implementing act states them. The official pictogram is not reproduced as production artwork. Fishing gear is excluded from Article 7 on the face of Part D and Recital 20; it is not listed here as a marking product.
Last verified: 22 August 2026.