AISDPCL is the Portuguese Association of Manufacturers of Soaps, Detergents and Maintenance and Cleaning Products. AISDPCL is a member of Detergents Europe, the European trade association representing the soaps, detergents and maintenance and cleaning products industry. AISDPCL represents companies that manufacture, import, and distribute these products in Portugal. The sector includes large, medium-sized, small, and micro-enterprises, spanning national, international, and multinational companies. AISDPCL´s key priority is to ensure that consumers have access to safe, innovative, and sustainable products, while maximising the industry's potential for innovation and growth.
AISDPCL supports the objectives and aims of 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 (the Single-Use Plastics Directive – SUPD):
- to prevent and reduce the impact of certain single-use plastic products on the environment, particularly the marine environment and human health;
- to promote the transition to a circular economy by fostering innovative and sustainable business models, products, and materials, while ensuring the smooth and efficient functioning of the EU internal market;
as amended by Regulation (EU) 2025/40 of the European Parliament and of the Council of 19 December 2024 on packaging and packaging waste (the Packaging and Packaging Waste Regulation – PPWR).
For that reason, AISDPCL would like to take the opportunity provided by the Single Market Transparency Directive (EU) 2015/1535 (SMTD) procedure to prevent the emergence of barriers in the internal market — specifically within the Iberian market — before they materialize. AISDPCL appreciates the opportunity to submit its contribution and express its main concerns regarding certain provisions of the notified Spanish Draft Royal Decree, which applies to single-use, pre-wetted domestic wipes (both plastic and plastic-free wet wipes) placed on the Spanish market, as well as to the waste generated by their use.
Portugal has remained faithful to the harmonized text of the EU Single-Use Plastics Directive (Directive (EU) 2019/904) by confirming Extended Producer Responsibility (EPR) and marking obligations exclusively to wet wipes containing plastics. In stark contrast, the Spanish Draft Royal Decree introduces gold-plating measures by extending EPR obligations to purely plastic-free alternatives. This unilateral extension lacks sufficient economic evidence, targets products outside the scope of the SUP Directive, and threatens the free movement of goods within the EU Internal Market under Article 34 of the TFEU.
Furthermore, the Spanish proposal creates an unlevel playing field that disproportionately burdens Portuguese exporters.
While the stated purpose of the Spanish Draft Royal Decree is to establish a legal regime for the management of waste generated by single-use wet wipes and balloons containing plastic — aiming to prevent and reduce their environmental and health impact through better waste management and a transition towards a circular economy — the actual provisions go much further.
Indeed, through the notified Draft Royal Decree, Spain adopts national measures — with a major impact expected on Portuguese operators — that go far beyond the scope and provisions of the Single-Use Plastics Directive (SUPD), introducing two additional requirements regarding wet wipes placed on the Spanish market:
- The application of Extended Producer Responsibility (EPR) obligations to plastic-free wet wipes; and
- The inclusion of sewerage and wastewater treatment infrastructure costs for wet wipes within those Extended Producer Responsibility (EPR) obligations,
which, from AISDPCL’s point of view, must be considered incompatible with the Internal Market and, in particular, with Articles 34 and 36 of the Treaty on the Functioning of the European Union (TFEU).
Please find attached AISDPCL’s detailed comments on the two additional requirements introduced by the Spanish Draft Royal Decree regarding single-use, pre-wetted domestic wipes (both plastic and plastic-free alternatives) placed on the Spanish market, as well as the waste generated by their use.
