A supplier cannot confer suitable technology status by declaration. Check the technology in Annex I, any requirement for individual process authorisation, the actual process and installation, and the intended use of the resulting material.
Can a machine manufacturer declare its technology a “suitable recycling technology” under Regulation (EU) 2022/1616?
No. “Suitable recycling technology” is a formal regulatory concept. It concerns a technology established as capable of recycling a specified waste stream into safe food contact materials and articles under the conditions laid down in the Regulation.
1. Technology is a general concept, not a description of one machine
The Regulation defines a recycling technology by a particular combination of physical or chemical principles, practices, waste type, collection arrangements and intended use of the output.
This is broader than an equipment brand or the trade name of a processing line.
2. “Suitable” means formally established capability
A technology can be established as suitable where its ability to produce materials meeting the general food contact material requirements and microbiological safety requirements has been demonstrated.
Detailed conditions for its use are set out in Annex I and, where applicable, in authorisations for individual processes.
3. Annex I is the reference point
At the date of the source review, suitable technologies include post-consumer mechanical PET recycling and recycling from product loops within a closed and controlled chain. The Commission’s overview checked on 5 October 2026 still identifies these two technologies.
The system is not necessarily fixed permanently. The Regulation allows new technologies to be developed and evaluated.
4. Mechanical PET recycling and closed and controlled chains differ
For mechanical PET recycling, individual process assessment matters because decontamination efficiency depends on configuration and operating conditions. Closed and controlled product loops rely on different mechanisms for controlling input and material circulation.
Requirements for one model should not be transferred to the other without checking which technology applies.
5. A recycling process is more specific than a technology
A recycling process is a particular sequence of operations: pre-processing, decontamination and post-processing, based on a given technology. Two processes may use a similar technological concept but have different configurations or parameters.
This is why certain technologies require each individual process to be assessed.
6. A recycling installation is the equipment at a particular facility
The installation is the physical system operating at a specific recycling facility. It should correspond to the process on which it is based and operate under the applicable conditions.
Registration and control connect the formal process description with actual production.
7. Individual authorisation does not automatically apply to every technology
The Regulation requires individual authorisation where safety depends on detailed process configuration and conditions that cannot be described adequately through simple general rules.
Annex I specifies individual process authorisation for post-consumer mechanical PET recycling.
8. Novel technology provides a route for developing new solutions
A technology that has not yet been established as suitable may be developed through the Regulation’s novel technology route. This entails additional documentation, monitoring and information publication obligations.
A solution under development as a novel technology should therefore not be presented as already formally suitable without checking its status.
9. The word “approved” can cause confusion
A technology supplier may use marketing descriptions, technical certificates or references to other systems. These do not automatically establish a status under Regulation (EU) 2022/1616.
Verification should cover the technology, the specific process, any applicable authorisation and the installation, rather than promotional material alone.
10. RecyClass Module A depends on the actual technology status
Module A was developed in connection with Regulation (EU) 2022/1616 and refers to suitable recycling technology. An auditor does not replace the regulator, but can check whether the organisation correctly identifies and controls its process.
The certification scope should be consistent with the actual technology status and the relevant stage of the chain.
11. Check five levels of information before investing
- Is the technology listed as suitable?
- Does it require individual process authorisation?
- Which process will actually be used?
- How will the installation be configured?
- What is the intended use of the final material?
Together, these elements provide a reliable basis for assessing the compliance of an investment project.
Frequently asked questions
Is every mechanical PET recycling solution a suitable recycling technology?
Post-consumer mechanical PET recycling is listed as a suitable technology. A specific process must nevertheless meet the conditions for that technology, including the applicable individual authorisation requirements and any relevant transitional arrangements.
Is RecyClass Technology Approval the same as suitable recycling technology?
No. They belong to different systems. RecyClass Technology Approval concerns packaging recyclability; suitable recycling technology is a concept in food contact legislation.
Can a chemical recycling technology be established as suitable?
The Regulation allows new technologies to be developed and evaluated. Check their current status in Annex I and Commission documentation.
Does one authorisation cover all installations using a process?
Distinguish the authorised process from the registration and control of the individual installations using it.
Does a RecyClass certificate confer suitable technology status?
No. The legal status follows from the Regulation and the actions of the competent EU institutions.