Everything’s new with EU 2022/1616


The new regulation on recycled plastic materials and articles intended to come into contact with foods (EU) 2022/1616 means many changes and new administrative requirements for recyclers and converters of food contact materials. The new regulation applies to all food and beverage packaging, therefore affecting approximately 44% of all plastic packaging in the European Union1. One year ago, it was adopted by the European Commission and is now valid since 2022, repealing the former regulation (EC) No 282/2008.


An important novelty is that the regulation classifies mechanical recycling technologies in suitable technologies (with and without individual approval) and novel technologies. Mechanically recycled PET after decontamination, and recycling of post-industrial inhouse waste, can continue to be produced and placed on the market as „suitable technology“. All others must be newly licensed as „novel technologies“, a process which is expected to be quite costly in terms of time and money.

Functional barrier - a question mark


The so-called “sheet with functional barrier” is an A/B/A sheet made from recycled material without prior decontamination, which is co-extruded between two layers of virgin material. The new regulation is not clear on how the issue of functional barrier will be handled in the future. It is regarded as “novel technology”, because the Commission considered that it cannot be guaranteed that a barrier layer will prevent the transfer of potential contaminants. A consortium of producers has submitted an application - but how long does it take for a decision by the European Commission, and will the decision then apply to all manufacturing companies, or not?


Right now, there is only uncertainty, and a lot of questions. Estimating how long an approval could take resembles an attempt of prophesy, because the regulation remains vague or unclear for too many details of this procedure. Five years minimum, say some. Ultimately, it is not certain if and when the evaluation of the functional barrier concept would be approved.



Monomaterial rPET sheet, the safe choice


But there is also good news for all those who manufacture packaging for food contact. For years viscotec has been offering a safe solution that is both approved and available: the deCON unit for decontamination of recycled flakes before the extrusion process. It is the safe choice to produce sheet from recycled PET, with recycled content of any desired ratio and up to 100%. Our customers benefit from the food safety compliance of the deCON technology according to EFSA and FDA, and our long-standing experience with food contact approvals.



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