Recycled Plastics in Food Contact

The bright line

Food-contact plastic is regulated as if every batch might end up wrapping a child's lunch, because it might. The consequence is a bright line the whole industry must respect: ordinary recycled plastic — however clean, however certified for content — is not permitted in food-contact applications. Recycled material reaches food contact only through specifically authorised recycling technologies operating under specific controls. A supplier who offers "food-grade rPET" without naming the decontamination technology and its authorisation is offering words, not compliance.

The regulatory framework

Regulation (EU) 2022/1616 on recycled plastic materials intended for food contact rebuilt the European regime (and the UK operates aligned provisions; references here are to the EU text as the corridor's common denominator). Its architecture:

• Suitable recycling technologies — the regulation defines which technology families may produce food-contact recyclate. The workhorse is post-consumer mechanical PET recycling with super-clean decontamination; each installation's process is assessed and registered.
• Registered processes and installations — individual recycling processes and the installations running them are listed in an EU register, with compliance monitoring obligations on the recycler.
• Input controls — the input must come from food-contact packaging collected in suitable systems; you cannot decontaminate your way out of an uncontrolled input stream.
• Quality management and documentation — batch-level records connecting input, process parameters and output.

What "super-clean" actually means

A super-clean process takes hot-washed PET flake — the product we supply as standard — and subjects it to deep decontamination: vacuum and high-temperature treatment, solid-state processing, surface removal, or combinations, validated by challenge tests in which surrogate contaminants are deliberately introduced and their removal measured. The output is rPET whose residual contamination is demonstrated, not assumed, to be below thresholds safe for food contact.

This is why the distinction we draw on our product pages is not commercial caution but chemistry: hot-washed flake is the input to food-grade rPET; it is never itself food-grade.

The Declaration of Compliance

Every delivery of food-contact material must be accompanied by a Declaration of Compliance (DoC) — a document in which the supplier states, with reference to the applicable regulation:

• the identity of the material and the authorised/registered recycling process behind it,
• the conditions of use it is compliant for (food types, time and temperature),
• any restrictions the converter or packer must respect.

Our food-approved PET sheet and food-grade rPET pellet ship with a DoC naming the super-clean technology and registration. Treat the DoC as you treat a certificate of analysis: file it per batch, and refuse delivery without it.

Common traps we see in the market

1. "Certified recycled" conflated with "food-safe" — GRS or RecyClass content certification says nothing about food contact. Different question, different regime.
2. Generic recyclate blended "below the radar" — there is no de-minimis recycled content that escapes the rules in a food-contact layer.
3. Functional-barrier claims without substantiation — multilayer structures can lawfully place non-compliant recyclate behind a barrier, but the barrier design must be demonstrated, documented and stated in the DoC, not asserted in a sales email.
4. Copy-paste DoCs — a DoC that names no process, no registration and no conditions of use is not a DoC; it is a disclaimer wearing a costume.

What to ask any supplier — including us

Ask for the DoC template before contracting; ask which registered process produces the recyclate; ask how input collection is controlled; ask what batch documentation arrives with each delivery. We answer all four in writing as a matter of routine. A market with a trust deficit is fixed by suppliers volunteering their evidence — that is the standard we hold ourselves to.

This page is general guidance, not legal advice, and does not replace your own food-contact compliance assessment. See the "last reviewed" date above.