Single-use plastics: classify the product before redesigning the portfolio

The practical starting point is a register that classifies the portfolio. A redesign begun without one tends to substitute the products that are most visible or most discussed rather than the ones actually affected, and to miss items that are affected but inconspicuous.

The register should carry, for each product, the information that determines its position: what the product is and the category it belongs to; the material or materials it is made from, including coatings and multilayer constructions that a simple material description may hide; what it is intended for and how it is used; and the market in which it is placed.

That last field is easy to overlook and important. A product placed on the market in one jurisdiction is not automatically in the same position in another, and a business selling across markets needs the register to distinguish between them rather than applying a single classification across the portfolio.

Material composition deserves particular care. A product described as paper may carry a plastic coating or lining that changes its position; a product described as plastic may be one of several polymers with different treatments; and a multilayer construction may combine materials in a way that a simple description conceals. The register should record what the product actually is, at the level of detail the classification requires.

Classification depends on what a product actually is, and the business buying it usually learns that from its supplier. That makes supplier evidence a critical input, and one that is worth treating critically.

Suppliers describe products in commercial terms, and a description adequate for a purchasing conversation is often insufficient for a classification exercise. A component described as 'paper' may be coated; a 'compostable' claim may refer to a specific standard and conditions that the product does not meet in the market where it is sold; a material may have changed since the specification was last reviewed.

The practical discipline is to ask for composition at the level of detail classification requires, to record when the specification was last confirmed, and to treat a change in supply as a trigger for re-classification rather than as a commercial detail. Where a supplier cannot provide the composition, that is itself information: the business cannot classify what it cannot describe.

Once the affected products are identified, the question becomes what replaces them — and this is where a classification exercise turns into an operational programme.

An alternative has to work in the operation, not merely exist. A replacement material or format may change how a product performs in service: how it holds, seals, insulates, stacks, prints, or behaves in a customer's hands. Where a product is used in a service setting, the change may affect the service itself — a different container may change portioning, presentation, handling time or the customer experience. The operational consequences belong in the assessment, because a substitution that performs poorly will be reversed, and the reversal costs more than the original assessment would have.

Cost per unit is not the comparison either. The relevant figure is the total cost of the change over the period it applies: the unit cost difference, any change in inventory and lead time, tooling or specification changes, staff training, and any effect on the customer proposition. A cheaper unit that degrades the service or increases waste is not cheaper.

Change control is what holds the programme together. Specifications change, suppliers substitute, and new lines are added. Without a route by which a change triggers a re-classification, a register that was accurate when built will drift out of date, and the drift will be discovered at the point where it is most expensive to correct. The register should therefore be a maintained document with a named owner, not a project deliverable filed at the end.

Finally, the boundary. Nothing here determines whether any particular product is or is not within scope of any rule, and nothing here is current compliance advice. The position for a specific product depends on the applicable rules at the relevant time, on the product's actual composition and intended use, and on the market. That determination should be made with the current text and, where the exposure is material, with qualified advice.