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KNOWLEDGE BASE / FOOD CONTACT

Recycled plastics for food contact

Safety starts long before decontamination

For recycled materials intended for food contact, controls cover waste origin, collection, sorting, pre-processing, decontamination, quality and traceability.

Frequently asked questions
Can any rPET be used in a beverage bottle?
Where must the waste come from?
How do Module Alpha, A1 and A2 differ?
What does the 5% non-food limit mean in mechanical PET recycling?
Does a RecyClass certificate automatically authorise food-contact use?
LEGAL BASIS

Commission Regulation (EU) 2022/1616 and related legislation

2022/1616
Recycled plastics for food contact
Specific requirements for technologies, processes, installations and the use of recycled material.
1935/2004
General safety of food-contact materials
General requirements for materials and articles intended to come into contact with food.
10/2011 + GMP
Plastics and good manufacturing practice
Material and manufacturing requirements considered alongside recycling legislation.
FOOD-CONTACT ARTICLES

From a waste stream to safe material

THE WHOLE FOOD-CONTACT CHAIN

Safety does not begin at the decontamination unit

Collection
Appropriate sources and separate collection systems.
Sorting
Control and traceability of the relevant stream.
Pre-processing
Sorting, shredding, washing and other operations preparing the plastic input.
Decontamination
Removing incidental contaminants to a level safe for the intended application.
MODULE ALPHA, A1 AND A2

The modules cover different stages of the chain

Module Alpha concerns the relevant Sorting Process stage for materials sent for further recycling into food-contact applications. Module A1 covers final pre-processing to prepare plastic input for decontamination, while Module A2 covers the decontamination process within the relevant scope.

A RecyClass certificate is not automatic authorisation for food-contact use
Certification can confirm specified procedures, controls and process traceability. It does not replace a full legal assessment, the relevant authorisation or the operator's responsibilities under food-contact legislation.
MECHANICAL PET RECYCLING

Appropriate technology, controlled input and validated decontamination

Regulation (EU) 2022/1616 recognises post-consumer mechanical PET recycling as a suitable technology subject to specified conditions. These include a maximum of 5% in the plastic input of the relevant materials and articles previously used in contact with non-food materials or substances.

appropriate origin and collection
control of pre-processing
validation of the decontamination process
challenge testing and critical parameters
relevant authorisations, where required

FROM WASTE TO FOOD-CONTACT MATERIAL

Safety depends on the whole chain, not only the final recycler

Regulation (EU) 2022/1616 governs recycled plastics intended for food contact. In practice, waste origin, collection, pre-processing, decontamination, process control and appropriate documentation all matter.

WASTE ORIGIN

Material sent for the relevant recycling operation should meet the source and collection requirements of the applicable technology and legislation.

SORTING AND COLLECTION

Traceability starts before decontamination. Appropriate sorting and input-stream control affect the safety of the subsequent process.

PRE-PROCESSING

Operations preparing material for decontamination must be clearly distinguished from decontamination itself and properly documented.

DECONTAMINATION

For the relevant processes, technological parameters and a demonstrated ability to remove contaminants are essential to meeting the requirements of the applicable recycling process.

AUTHORISATIONS AND RESPONSIBILITY

An industry scheme certificate does not replace required authorisations, operator obligations or the legal assessment of the material and its intended application.

DOCUMENTATION

Information about input material, process parameters, output and conditions of further use must be consistent and traceable.

RELATED AREAS

Check the earlier stages of the material chain

For food-contact materials, what happened to the waste and plastic before the final recycling stage matters.

FOOD CONTACT

Unsure where sorting ends and pre-processing or decontamination begins?

The scope must be determined from the actual operations, material status and applicable legal requirements.