Food Contact Materials Regulation (EU) 2022/1616 [the Regulation] establishes strict requirements for recycled plastics intended for food contact, covering the entire value chain from collection to final product.
In a joint webinar with ICIS, Plastics Recyclers Europe (PRE) and members of the value chain outlined some of the challenges around the collection and pre-processing steps.
The Regulation mandates separate collection of plastic waste, pre-processing, compliance with EU food-contact rules (notably Regulation (EU) 10/2011), and third-party certification of quality assurance systems to ensure safety and traceability.
While EU recyclers benefit from existing compliance frameworks and suitable technologies (like PET mechanical recycling), non-EU recyclers face significant hurdles—proving equivalence to EU standards, implementing traceability systems, and undergoing a lengthy process of gathering and submitting data for novel technologies for approval by the European Food Safety Authority (EFSA), which can take up to five years.
These requirements aim to safeguard food safety when using recycled plastic materials while supporting the EU’s recycled content targets, but they could pose major challenges for global supply chains.
Regulation (EU) 2022/1616 – Key Points
Applies to all recycling processes producing plastics intended for food contact (mechanical, chemical, physical, closed-loop).
Requirements cover:
- Separate collection of plastic waste.
- Pre-processing activities (sorting, shredding, washing).
- Decontamination units, and
- Post-processing
Related to these requirements:
- Compliance with EU 10/2011 for food-contact safety of the original polymers.
- Third-party certification of quality assurance systems for traceability.
Suitable vs. Novel Technologies
The starting point is to qualify the technology status under the regulations and in line with the EFSA assessment. There are two technology statuses:
- Suitable technologies: Post-consumer PET mechanical recycling and closed-loop systems
- Novel technologies: Require multi-year approval (up to 5 years when extension periods are included) with extensive safety data before listing in Annex I of the Regulation.
Challenges for Non-EU Recyclers
- Must prove compliance with EU 10/2011 via national law or detailed equivalence checks.
- Implement traceability systems and secure EU-recognized certification.
- Face long approval timelines and high costs for EFSA evaluation.
- Separate collection standards may not exist locally, adding complexity.
Strategic implications
The European Commission has set out mandatory recycled content targets for contact sensitive material from 2030 onwards under the Packaging and Packaging Waste Regulation (PPWR), which adds to the existing targets under the Single Use Plastics Directive.
The EU market will need higher volumes of recycled material to meet those 2030 packaging targets. PPWR alone will generate 11.5 million tonnes of additional demand for recycled PET, PE and PP by 2040.
“Meeting those targets will require imports to compliment European supply, but recyclers outside the EU are already struggling to understand the complex legislative landscape they need to navigate in order to be part of the solution”, said Helen McGeough, Global Analyst Team Lead for Plastics Recycling at ICIS.
Non-EU recyclers must invest in compliance infrastructure or partner with EU-certified entities, if they aim to supply into the European market.
Early alignment with a certification system, such as RecyClass, and QA systems is critical for market access for all operators in the European market.
