PET recycling for food contact: input to decontamination tested to Annex A of ISO 12418-2:2012 — at most 500 ppm labels and other visible contaminants, 200 ppm PVC and 500 ppm polyolefins including adhesive — and declarations of compliance P, A, B and C
Commission Regulation (EU) 2026/2376 of 28 October 2026, published in the Official Journal of the EU on 29 October 2026, amends Regulation (EU) 2022/1616 on recycled plastic materials and articles intended to come into contact with foods. For technology No 1 — post-consumer mechanical PET recycling — washed and dried post-consumer PET waste must give the results m1/m0 ≤ 500 ppm, m2/m0 ≤ 200 ppm and m3/m0 ≤ 500 ppm in a test according to Annex A of ISO 12418-2:2012 (or by a method with equivalent or higher performance); the regulation enters into force on 18 November 2026.
- What the test measures (ISO 12418-2:2012, Annex A — method for the determination of impurities in PET flakes): about 100 g of flakes (mass m0) are spread over a tray with a bottom of at least 0.05 m², and for at least 30 min pieces of label and other visible contaminants are picked out with tweezers (m1); the tray then goes into a forced-air oven at 220 °C for 1 h. After cooling, the black carbonised PVC particles (m2) and the yellowed particles of polyolefins and adhesive (m3; the adhesive may be indistinguishable from them) are picked out and weighed on an analytical balance to 0.0001 g, and the content in mg/kg is m × 10⁶ / m0 — so the limits mean at most 500 mg/kg labels and other visible contaminants, 200 mg/kg PVC and 500 mg/kg polyolefins including adhesive.
- Until now Table 1 of Annex I required for this technology only that post-consumer PET waste contains at most 5 % of materials and articles used in contact with non-food materials or substances; recital 11 notes that there were no rules on the detailed specifications of pre-processed plastic input such as those reported in Appendix A to the EFSA opinions on recycling processes. Batches of plastic input are accepted for decontamination only with a Declaration P (kept by the recycler for at least 5 years), each batch of plastic has a single quality record with a unique number, and recycled plastic may come only from installations with the status “newly registered”, “being established” or “active”.
- Declarations of compliance are required at every marketing stage other than retail (food business operators packing food need not pass them to retailers when the information is given by labelling or other documentation): P for partially pre-processed plastic input and plastic input, A issued by the recycler for batches directly from decontamination, B by the converter after post-processing, and a new simplified Declaration C for recycled plastic whose composition no longer changes (no new batch numbers, a list of the recycling installations used; adding substances up to 1 % (w/w) in total is not a change of composition). Off-cuts and scraps of recycled plastic may be added during post-processing under the reprocessing rules of Regulation (EU) No 10/2011, and supporting documentation must be made available to the authorities within 10 working days.
- Register and customs: decontamination installations are registered in a non-public electronic registration system at least 30 working days before production starts, some of the statuses (from “newly registered” to “decommissioned”) change automatically, and the recycler confirms the data every six months. When recycled PET for food contact is released for free circulation (including CN codes ex 3907 61 00, ex 3907 69 00 and ex 3915 90 20, bottles, films, packaging and tableware), Declaration P, A, B or C is presented to customs; old Declarations A and B suffice until 18 February 2027, and Declarations C and P may be missing until 18 May 2027.