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EU Regulation on Food Contact with Recycled Plastic Materials and Articles

Date:2022-10-31 10:10:57 Classification :【Statute】 Visits:

On September 20, 2022, the European Commission approved and issued Regulation (EU) 2022/1616 on food contact recycled plastic materials and articles, and repealed Regulation (EC) No 282/2008. The new regulations have come into force on October 10, 2022.


Regulatory requirements: From October 10, 2024, the quality assurance system for plastic waste collection and pretreatment shall be certified by an independent third-party organization. From October 10, 2024, the input batch and output batch of the purification process must be analyzed and tested by the laboratory to determine the pollution level.


Scope of Application


This Regulation establishes rules on:


Launch of recycled plastic materials and articles in contact with food (i.e. plastic materials and articles within the scope of Article 1 (2) of Framework Regulation (EC) No 1935/2004 on Food Contact Materials (FCMs), which contain plastics derived from waste or plastics made from waste);

Development and operation of regeneration technology, process and device for producing renewable plastic materials in contact with food;

Use or intend to use recycled plastic materials and articles in contact with food.


Requirements for recycled plastic materials and articles


Recycled plastic materials and articles can be put on the market only if they meet all the following requirements during the manufacturing process:


Comply with Chapter II (Composition Requirements), Chapter III (Specific Requirements for Certain Materials and Articles) and Chapter V (Migration Limit Requirements) of the Plastic Food Contact Regulation (EU) No 10/2011;

The "suitable recycling technology" listed in Annex I of this Regulation is used for manufacturing, or the "new technology" described in Chapter IV of this Regulation is used for manufacturing;

The manufacture of the recycled plastic has been registered in the Union register. And the state of the authorized regeneration process of the manufacturing is not "suspended" or "revoked".

The regulations have detailed requirements for the manufacturing process using "appropriate regenerative technology" and the manufacturing process using "new regenerative technology".


At present, there are two specific "suitable regeneration technologies" listed in Appendix I, namely: (1) post consumer mechanical PET recycling and (2) recycling from product loops which are in a closed and controlled chain. Each separate process of the former must be authorized, but no recycling scheme is required. The latter does not require authorization for each individual process, but requires a regeneration plan.


The regulations also specify general requirements for the recycling of plastics and the use of recycled plastics in the following areas:


Collection and pretreatment;

purify;

Post processing and use;

Operation of regeneration plan;

Among them, the quality assurance system for collection and pretreatment shall be certified by an independent third party (implemented from October 10, 2024).


Requirements for documents, instructions and labels


Each batch of recycled plastics, recycled plastic materials and articles shall have a single document or record related to their quality. It shall be identified by a unique number and the name of the manufacturing stage from which it originates.

Recycled plastics placed on the market shall be accompanied by a declaration of compliance (DoC) in accordance with Article 29 of this Regulation.

The recycled plastic containers delivered to the converter shall be labeled.

The label shall show the symbols in Annex II to FCMs Framework Regulation (EC) No 1935/2004:



And followed by the following symbols and information:


The symbol, and the registration number of the purification device used for recycled plastics;

Symbol followed by the batch number;

Weight percentage of regenerated components;

If the weight percentage of recycled ingredients contained in the final recycled plastic materials and articles is less than 100%, the maximum weight percentage of recycled ingredients shall be indicated; as well as

When the declaration referred to in paragraph 2 provides additional instructions, the symbol in ISO 7000 with reference number 1641 must be indicated:



Regulations specify the minimum font size requirements on labels.


Transition Period


1. For the recycled plastic materials and articles obtained based on the regeneration process of "appropriate regeneration technology", if this Regulation requires separate authorization of the regeneration process, and (1) the applicant has submitted a valid application to the competent official department in accordance with the requirements of Article 5 of Regulation (EC) No 282/2008, or (2) the applicant has submitted an application in accordance with Article 17 (1) or Article 22 (1) of this Regulation on or before July 10, 2023, before the applicant withdraws his application, Or it can be put on the market before the European Commission makes a decision to approve or refuse to authorize the regeneration process;


2. The recycled plastic materials and articles obtained from the regeneration process of the regeneration technology considered unsuitable by this Regulation can only be put on the market until July 10, 2023. Unless they are manufactured by regeneration devices for the purpose of developing "new regeneration technology".


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