The maximum 5% by weight refers to PET from previous non-food uses in the specified recycling input. It is separate from overall PET purity and contamination limits. Meeting this parameter alone does not establish full food-contact compliance.
Does the 5% limit mean that input material may contain any 5% of contaminants?
No. This is one of the most frequently misinterpreted provisions in food-contact recycling. The Annex I limit concerns the proportion of PET from non-food applications in the input for post-consumer mechanical PET recycling. It is not a general allowance for 5% of any plastics, metals, paper, PVC, food residues or other contaminants.
1. The limit comes from Annex I to Regulation 2022/1616
For the technology “post-consumer mechanical PET recycling”, Annex I specifies PET post-consumer waste containing a maximum of 5% materials and articles previously used in contact with non-food materials or substances.
The value is a maximum proportion by weight. It is not a production target or a level to work towards deliberately.
2. The 5% concerns non-food PET, not all foreign materials
A site may also control other polymers, labels, adhesives, metals, product residues and many other unwanted components. Separate quality and process requirements apply to these elements.
It would be incorrect to say: “We have 4% PVC and other contaminants, so we are below the 5% limit.” These are different parameters.
3. Non-food describes the packaging’s previous use
Examples include PET packaging previously in contact with a non-food product. Input control must distinguish such applications from PET used for beverages or other appropriate food products.
The material’s use history is decisive, not simply whether a spectrometer identifies it as PET.
4. The limit is part of a broader input-control system
Meeting the 5% limit does not remove requirements concerning waste origin, separate collection, input quality or traceability. It is one parameter within a wider system.
Material can contain less than 5% non-food PET and still fail other Article 6 conditions or the requirements of the particular process.
5. Control should follow a defined method
The company should know how it assesses the proportion of non-food materials. Its method may include appropriately designed sampling, manual classification, visual inspection or another approach suited to the stream and system requirements.
The result must be repeatable, documented and linked to a specific batch or production period.
6. A supplier cannot be the only source of assurance
A supplier declaration is important, but the quality system also needs verification. The frequency and scope of checks should account for risk, supplier history and variation in the stream.
Omitting checks simply because “we have bought from the same sorting plant for years” weakens the system’s credibility.
7. Module Alpha can help control the parameter earlier in the chain
Under Sorting Process Module Alpha, control of origin, separate collection, segregation and material composition takes place before actual recycling. This can provide the recycler with a better-documented stream.
It does not remove the recycler’s responsibility for its own input requirements and checks on received material.
8. A1 and A2 cover different stages from sorting itself
Module A1 concerns final preparation of input material for decontamination, while Module A2 concerns the decontamination process itself. Checks on the non-food PET limit may therefore occur at several points in the chain as part of broader input quality control.
Each operator should understand the stage for which it is responsible and the evidence it passes downstream.
9. The 5% maximum is not a target for every batch
To meet the requirements consistently, the system should minimise the risk of exceeding the maximum. An internal alert threshold below the limit can be a reasonable risk-management tool.
The approach should reflect material variability and the reliability of sampling data.
10. Exceeding the limit calls for holding and investigating the batch
A batch with a result above the specified maximum should not automatically be “diluted” without assessment. First identify the cause, the extent of the problem and its effect on traceability.
Corrective action should be documented, and the decision on further handling must comply with process and quality-system requirements.
11. Confusing different measures is a common mistake
In practice, three different indicators are encountered: the proportion of non-food PET, overall PET purity, and the proportion of other materials and contaminants. They may use different measurement methods and criteria.
Documentation must clearly identify the parameter being measured. A statement such as “purity >95%” does not establish that the non-food PET limit is being controlled.
Frequently asked questions
Does 5% mean 5% of all non-food packaging?
For post-consumer mechanical PET recycling, it means the maximum proportion by weight of PET from previous non-food uses in the specified input.
Are labels and caps included in this 5%?
They should not automatically be equated with the non-food PET limit. Foreign components are also controlled under separate input quality requirements.
Does a result of 4.9% mean the process is fully compliant?
No. It is only one parameter. Requirements for origin, collection, composition, process, documentation and traceability must still be met.
Can the company rely solely on a supplier declaration?
The system should provide appropriate input-material verification and retain evidence supporting the result.
Does RecyClass verify this limit?
The relevant modules may include material-control requirements, but certification should not be presented as a substitute for a complete assessment of legal compliance.