EU Legislation

Repealed EU Legislation     Current EU Legislation    Future EU Legislation   EU guidelines

Topics:     Active and Intelligent Materials      GMP     Introduction     Recycling     Traceability

Recycling of plastics

In the EU plastics may be recycled and be used in contact with food contact materials if they are safe and in compliance with the new recycling legislation. Click here for the recycling regulation.

Different types of recycling can be distinguished as is schematically given in the following scheme:

The new legislation does apply to secondary recycling only. It does NOT apply to:
 • Primary recycling
 • Tertiary recycling
 • Recycled plastics behind a barrier

It is possible that audits are performed by the authorities. Labeling of the recycled content of final materials and articles is voluntary. Guidelines for preparation of a technical dossier will be issued by EFSA 6 months after the publication of Regulation in the OJ

EU requirements
• Input must be food compliant
• Processes authorized, not sites!
• Recycling process must be
  - validated using a challenge test or using a closed loop
  - authorised by EU
  - managed under quality system (EC) 2023/2006, which will be amended to include new requirements for recycled materials
• Final product must meet requirements of Plastics Directive and Framework Regulation

Preparation of EU recycling dossier

A recycling dossier must be filed to the EU to get an approval for the recycling system. The dossier does consist of the following item:
• The name and address of the applicant
• Name of the process
• Characterization of the input
• Description of the challenge test or closed loop system
• Characterization of the recycled material
• Description of any restrictions on the conditions of use for recycled material
• A summary of the dossier.

EU technical dossier
• Name and address of the recycler
• Detailed description of the recycling process
• A risk analysis of the recycling process + critical points + measures taken to minimize and control the risk
• The food contact applications covered
• The specifications of the plastic output: plastic output intended for the manufacture of plastic materials and articles to be used in a specific food contact application should meet the requirements that are appropriate for this use
• Protocol and results of the challenge test performed


More information can be found in two presentations given:

Washington DC, USA 3-4 October 2007 Recycled Plastic, Regulatory Guidelines in the EU
Paris, France 8 November 2007 Le contexte et cadre réglementaire
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