High sorting purity does not automatically satisfy separate collection requirements. Assess the collection system, previous use, material origin and traceability to first sorting, alongside the quality assurance arrangements required for the relevant stream.
Does a very clean PET bale sorted from mixed waste meet the separate collection requirement?
Not automatically. For food contact recycling, the quality of the final stream matters alongside its origin and previous collection method. Article 6 of Regulation (EU) 2022/1616 establishes requirements that begin before the sorting facility and recycler.
1. Waste origin is part of process safety
Not all PET waste can be treated as equivalent when recycling for food contact applications. Its history affects the possible level of unknown contamination, which is why the Regulation controls waste origin.
Article 6 primarily addresses municipal waste and waste from food retail or other food businesses where the material was intended and used for food contact, taking account of the specific cases allowed by the legislation.
2. Separate collection is more than subsequent PET separation
The requirement concerns how the waste was collected. Effective sorting at a later stage does not automatically change the stream’s history.
If PET bottles were recovered from residual waste, the stream should not be described as meeting the separate collection requirement without an applicable basis for doing so.
3. The Regulation allows specified separate collection models
One model collects only the relevant plastic materials and articles separately from other waste. Another allows joint separate collection with other packaging fractions or specified fractions of plastic, metal, paper or glass.
In the latter case, the system must concern non-hazardous waste, remain separate from residual waste, and minimise contamination by non-compliant materials during collection and subsequent sorting.
4. Waste from a food business still needs assessment
Waste from a supermarket, bottling plant or food factory is not automatically suitable simply because it originates in the food sector. Previous use and collection arrangements must be established.
Documentation should demonstrate that the stream meets the requirements of the relevant process, rather than rely solely on a statement that it is “waste from a food business”.
5. Control also covers the materials from which the waste originated
Article 6 links waste origin to requirements for the materials and articles that became waste. In practice, reliable knowledge of the stream is needed; colour or final purity alone is insufficient.
This is particularly important for international streams, mixed supply sources and intermediaries.
6. Quality assurance must operate during collection and pre-processing
The Regulation requires quality assurance systems throughout collection and pre-processing. They must ensure the material conditions are met, limit incidental contamination and enable documented batch control.
A one-off quality test is insufficient. Procedures, responsibilities, assessment methods, records and actions for material that fails acceptance criteria are needed.
7. Traceability must reach back to first sorting
The quality assurance system should make it possible to trace each batch to the point of first sorting of the collected plastic waste. The material’s history cannot begin only at the recycler’s gate.
If a secondary sorter or waste trader operates between the first sorting facility and the recycler, each stage should preserve continuity of the material information.
8. Independent attestation of the quality assurance system matters
Article 6 requires the quality assurance systems for collection and pre-processing to be certified by an independent third party. This distinguishes an internal company procedure from external confirmation of the system.
The scope of any particular certification must nevertheless be compared with the full legal requirement.
A certification mark should not be used as shorthand for full compliance of the entire chain.
9. Module Alpha addresses this earlier stage of the chain
RecyClass Module Alpha extends Sorting Process Certification with requirements for relevant streams intended for food contact recycling. It focuses on areas including origin, separate collection, segregation, quality control and traceability.
Module Alpha is not a food contact approval. It assesses specified controls within the sorting stage and relevant waste trader activities.
10. A good bale does not correct an earlier collection failure
For example, a facility receives mixed municipal waste and then uses optical sorting to recover high-purity PET. The resulting bale can be of very good quality, but the earlier collection method still needs assessment.
For food contact applications, final purity and compliant input origin are separate requirements.
11. Useful evidence to prepare
Relevant evidence includes supply contracts and specifications, a description of the collection system, identification of suppliers and sorting points, transport documents, incoming inspection records, composition analyses and rules for segregating compliant and non-compliant material.
The documentation should connect an individual batch with its history, rather than merely describe the system in general.
Frequently asked questions
Can mixed-collected waste later be considered separately collected?
Later separation alone does not change the earlier collection method. Assess each case against Article 6 and the current requirements for the relevant stream.
Is joint collection of plastic, metal, paper and glass always prohibited?
No. The Regulation permits joint separate collection of specified fractions, subject to additional conditions and separation from residual waste.
Must the first sorting facility be identifiable?
The quality system must enable each batch to be traced to the first sorting point of the collected plastic waste.
Does Module Alpha replace the quality assurance system required by law?
Do not assume automatic equivalence. Module Alpha can support verification of specified requirements, but legal compliance must be assessed against the full Regulation.
Does waste origin affect the subsequent challenge test?
A challenge test primarily assesses process decontamination efficiency. Input characteristics and quality remain separate requirements of the overall food contact system.