Recycled Plastics in Food Contact: EFSA, FDA and the Decontamination Challenge

EU 2022/1616 distinguishes three operator categories: the recycling installation (which decontaminates), the recycling scheme (which controls inputs and outputs), and the converter (which incorporates recycled plastic into the article). Each is registered with the Commission and assigned a recycler registration number that appears on the DoC. The regulation lists the suitable recycling technologies — currently the post-consumer PET mechanical recycling process is the principal authorised technology — and requires every other technology (chemical recycling, novel mechanical processes, behind-the-shop loops) to go through EFSA scientific evaluation before commercial use. The recurring confusion is that a converter cannot rely on the recycler's authorisation alone; the converter must hold its own DoC and supporting documentation linking the recycled input to the finished article.

The EFSA evaluation rests on a challenge test in which the input flakes are contaminated with surrogate substances (typically chloroform, chlorobenzene, toluene, phenylcyclohexane, methyl stearate, benzophenone) at defined concentrations, run through the candidate process, and the residuals measured in the output pellets. EFSA's safety logic is that the process must reduce the surrogates by enough that the worst-case migration into food stays below the 0.0025 µg/kg bw/day exposure threshold for non-genotoxic carcinogens. The FDA NOL route uses a parallel challenge — chloroform, chlorobenzene, toluene, phenyl heptane, methyl stearate, benzophenone, copper salt — with a residual-concentration logic that maps to the FDA threshold-of-regulation. A challenge run on lab-scale flakes has no defence if the commercial line operates at higher throughput or different residence time; the challenge must be representative of production.

The single biggest determinant of recycled-plastic food-contact safety is the input. 2022/1616 requires that the input come from a closed and controlled loop or from materials that were originally manufactured under good manufacturing practice for food contact. For PET that effectively means deposit-return systems or carefully sorted curbside streams; for HDPE and PP the closed-loop route is dominant because curbside PP/HDPE is too contaminated. The 2024 EFSA opinions on rPP and on physical-recycling processes for non-PET polymers have set tighter input-quality expectations. A converter buying recycled flake without batch-level traceability to the recycling installation has no DoC defence under 2022/1616.

PPWR sets minimum recycled-content targets for contact-sensitive packaging — 30 % for PET bottles from 2030, 10 % for other beverage bottles, plus targets for contact-sensitive packaging in general. The claim itself is governed by EN 15343 (mass balance and controlled blending) and ISO 14021 (self-declared environmental claims), with EU-wide methodology in preparation under PPWR Article 7. A '30 % recycled' claim made on a controlled-blending basis must be substantiated by lot-level mass-balance records linking finished article output to recycled input. A claim made on a marketing-spec basis without traceable mass balance is the recurring finding in greenwashing investigations across DG ENV, DG GROW and US FTC enforcement.

Days 1–15: map every recycled grade to its recycling installation, technology authorisation (EFSA opinion / FDA NOL) and input-stream provenance. Days 16–30: refresh the decontamination challenge evidence — is the lab-scale challenge still representative of production? Days 31–45: lot-level mass-balance records for any recycled-content claim under EN 15343 / ISO 14021. Days 46–60: DoC reissue under 2022/1616 with the recycler registration number, the technology reference and the converter-side supporting documentation in inspection-ready form.