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.
