A technical data sheet or a supplier's “food-grade rPET” statement does not replace the declaration of compliance required under Regulation 2022/1616. The declaration identifies the operator and product, states the basis of compliance and communicates the instructions and restrictions needed downstream.
Can a TDS or a supplier's “food-grade rPET” statement replace the declaration of compliance?
No. Regulation 2022/1616 provides specific declaration templates for recyclers and converters. The document identifies the operator and product, states the basis for compliance and passes on restrictions and instructions needed by subsequent supply-chain operators.
1. The declaration maintains continuity of information
Recycled plastic placed on the market should be linked to a declaration of compliance. Its purpose is to give the recipient the information required for safe further processing, rather than simply obtain a signature.
The declaration works alongside batch traceability, container labelling and other process documentation.
2. Annex III contains two different templates
Part A of Annex III is intended for recyclers. Part B applies to converters where the material or article they process contains recycled plastic.
The same form should not be copied indiscriminately for every supply-chain stage. The operator's role determines the appropriate template and information.
3. The recycler identifies itself, the product and the competent authority
The template includes recycler details, identification of the recycled plastic product, the batch and relevant registration numbers where applicable. It also identifies the competent authority.
This allows the recipient to connect a delivery with a particular operator and the relevant registration system.
4. State the basis on which the process operates
The compliance section provides for references to an authorisation decision, a recycling scheme, a case where authorisation is not required or a novel technology, as applicable.
A general statement that the process is approved may be insufficient without identifying the formal basis.
5. The declaration can include or refer to quality assessment results
The template provides for results from mandatory quality assessment stages or confirmation that the required information will be made available to the competent authority on request, as set out in the form.
The company must maintain records enabling it to supply that information. The field should not be treated as a purely administrative checkbox.
6. Instructions for the converter are essential
Article 29 requires the recycler to provide sufficient instructions for further processing the recycled plastic into compliant materials and articles. These instructions follow from the technology's conditions and, where applicable, the particular process.
They may include the maximum recycled content, application restrictions and other relevant conditions.
7. The document also communicates actual recycled content
The recycler's declaration provides fields for the actual recycled content and, where applicable, the maximum permitted content in the final article.
This information should not be confused with recycled-content certification under another scheme or with PPWR obligations.
8. The converter passes compliance information downstream
A converter processing recycled plastic into further materials or articles has its own declaration template. It should take account of information received from the recycler and the conditions arising from subsequent processing.
Responsibility and information therefore continue down the chain instead of stopping with the first rPET recipient.
9. A DoC is different from a TDS, CoA or certificate
A technical data sheet describes product properties. A certificate of analysis can report results for a particular batch. A RecyClass certificate confirms the scope of a particular scheme. A declaration of compliance has a separate legal function.
The documents can complement each other but should not be treated as interchangeable.
10. Restrictions must be passed on
If a material cannot be used under particular conditions, such as certain contact times, temperatures or applications, that information must not disappear after the next processing step.
Failing to communicate a restriction can result in use outside the conditions for which compliance has been established.
11. The 2022/1616 declaration differs from the PPWR declaration
PPWR establishes its own conformity assessment and packaging documentation framework. The declaration for recycled plastic food-contact materials serves a different legal purpose.
A company producing rPET packaging may therefore need to manage several distinct layers of compliance documentation.
FAQ
Can a recycler use any form it chooses?
The Regulation provides the description and template in Annex III, Part A, as the reference for the recycler's declaration.
Does the converter also issue a declaration?
Yes. Annex III, Part B, provides the converter's declaration where the product contains recycled plastic.
Does the declaration certify final packaging PCR content under RecyClass?
No. It may include recycled-content information, but certification of recycled content is a separate matter.
Does a DoC replace migration test results?
It should not be treated as a substitute for all supporting evidence. The declaration relies on the wider compliance documentation and conditions relevant to the product.
Can supplier restrictions be lost after regranulation or preform production?
No. Relevant instructions and restrictions must be taken into account at subsequent supply-chain stages.