A Commission regulation published on 14 July 2026 amends Regulation (EU) 2022/1616 on recycled plastic food contact materials, introducing new compliance documentation, customs controls, and an electronic registration system for recycling installations. The rules tighten traceability and enforcement for recycled plastic used in food contact articles, affecting operators, importers, and competent authorities.
The regulation, adopted by the European Commission and notified to the Council, introduces two new declarations: Declaration C for post-processed recycled plastic at the final production stage (simplified, without batch numbers) and Declaration P for pre-processing stages and plastic input batches. Food businesses packing food with recycled content are not obliged to provide a declaration of compliance if they give instructions via labelling, but must provide it within 10 working days upon request by a competent authority or 20 working days upon request by a retailer or distributor.
release for free circulation requires presentation of compliance documentation for products under specific CN codes covering tableware and kitchenware with recycled plastic, and multi-layer sheets with recycled PET behind a functional barrier. Packaged food, food processing equipment, and appliances are excluded from these customs requirements.
operators must enter or modify information directly under competent authority supervision. Managers must inform the authority at least 15 working days before scheme operation, and developers must register novel technology at least 6 months before first decontamination installation operation.
products with existing Declarations A or B have 3 months after entry into force to comply; products requiring new Declarations C or P have 6 months. Manufacturing from such products is allowed until stock exhaustion.
Supporting documentation must be available at the time of declaration issuance and submitted to the competent authority within 10 working days. Off-cuts and scraps may be added to recycled plastic during post-processing if accompanied by Declaration B or C with information per Annex IV point 10 of Regulation (EU) No 10/2011. Recyclers must retain Declaration P for at least 5 years, and batch records for at least 5 years.
ISO 12418-2:2012 for pre-processed plastic input specifications, with other methods allowed if equal or better performance.
Recyclers face new administrative burdens for declarations and electronic registration, with compliance costs for updating systems and retaining records. Importers of recycled plastic food contact articles must present customs documentation, potentially slowing release. Competent authorities gain oversight through electronic registration and shorter response times for documentation requests. Food businesses using recycled packaging benefit from exemption from routine declarations but must be prepared to provide documentation on demand.
The regulation enters into force on the twentieth day following its publication in the Official Journal of the European Union.