A cover note from the Council of the European Union, dated 14 July 2026, transmits a Commission regulation amending Annexes I and III to Regulation (EU) 2022/1616 on recycled plastic materials and articles intended to come into contact with foods. The amendments update the Union register, compliance documentation, test methods, and documents required for release for free circulation, directly affecting operators handling recycled plastic for food contact.

The document, a Commission regulation adopted on 14 July 2026, replaces Table 1 in Annex I with new specifications for recycling technology 1 (post-consumer mechanical PET recycling). The plastic input must be washed and dried PET PCW with a maximum of 5% non-food contact materials. Test results according to ISO-12418-2:2012 or equivalent must show m1/m0 ≤ 500 ppm, m2/m0 ≤ 200 ppm, and m3/m0 ≤ 500 ppm. Output decontaminated PET must not be used in microwave or conventional ovens. Documentation upon release is required under code "Yes (6.1)". A new Table 6 lists CN codes for PET (e.g., ex 3907 61 00, ex 3923 30 10) with required Declaration P, A, B, or C.

Annex III is replaced entirely, providing templates for Declarations P (operators, Article 6(1)), A (recyclers, Article 29(2)), B (converters, Article 29(3)), and C (operators, Article 29(4)). Each template includes sections for identification, compliance, instructions, and signature. Declaration P requires origin (EU/non-EU), mode of collection (DRS, PCW, NTC), and quality assurance certification. Declaration A requires basis for authorisation (e.g., RAN, RSN, NTN) and compliance assessment results. Declaration B requires origin RIN number, recycled content, and restrictions. Declaration C requires total plastic content, recycled content per part, and compliance statements.

The regulation tightens technical requirements for PET recycling input and output, imposing stricter limits on non-food contact material content and contamination levels. This increases compliance costs for recyclers and converters, who must update testing protocols and documentation. However, it enhances consumer safety by ensuring recycled plastic food contact materials meet higher purity standards. The new declaration templates standardise compliance documentation across the supply chain, reducing administrative burden for operators already using the system. The regulation also clarifies customs procedures by linking CN codes to specific declarations, facilitating enforcement by national authorities.

The amendments apply directly in all member states. Operators must use updated Annex I specifications and new Annex III declaration templates for recycled plastic food contact materials, with specific PET input/output limits and documentation codes. The regulation enters into force on the twentieth day following its publication in the Official Journal of the European Union.

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