Traceability Era Begins for Food-Contact rPET

The rulebook for recycled plastics in food contact is tightening. On the packaging side, the compliance debate that came to a head when the PPWR entered into application on 12 August is now shifting to a more technical question: how will you document where a batch of rPET came from and which process it passed through?

A Revision to EC 2022/1616 Is Close

An amendment is being prepared to Regulation (EU) 2022/1616, which governs recycled plastic materials intended to come into contact with food. The draft, notified to the World Trade Organization in April 2026, redefines declaration-of-compliance requirements, updates the governance model of the EU register, and introduces clearer customs rules for imported recycled plastic products. Adoption is expected by the end of September 2026.

The core rule of the regulation is already unambiguous: only recycled plastic produced through processes authorised by EFSA (the European Food Safety Authority) may be used in food-contact applications. What the revision changes is that this authorisation can no longer stay on paper; it has to be demonstrated concretely at import and in the declaration of compliance.

What Changes for Importers

For producers shipping recycled plastic products into the EU, the documentation burden at customs increases. Because the content of the declaration of compliance is being clarified, “my supplier is certified” will no longer be enough: which process, under which registration number, was used for which batch must be traceable.

In practice, a declaration of compliance that survives scrutiny needs to connect four things that were often kept in separate files:

• the identity of the recycling process and its entry in the EU register of authorised processes;
• the EFSA opinion the authorisation rests on, so the assessed decontamination performance can be checked;
• the batch or lot number actually shipped, linked to that process rather than to the plant in general;
• the origin and quality of the input, since an authorised process fed with unsuitable input does not produce a compliant output.

The fourth point is where most supply chains are still thin, and it is exactly the point the second development below addresses.

RecyClass Has Launched Sorting Process Certification

Independent certification is moving in the same direction. In early 2026 RecyClass published a new Sorting Process Certification covering the input requirements for food-contact recycled plastics. Sorting facilities and waste traders involved in preparing material before recycling can apply for it.

This closes a link that has been missing in the industry for a long time: even when a recycling plant’s own process was authorised, how the input arriving at that plant had been collected and sorted often could not be documented. In food-grade production, where input quality directly determines output safety, that gap was critical.

The gap mattered commercially as well as technically. A recycler buying bales on the open market inherits whatever collection history those bales carry, and that history is what determines the share of non-food packaging, the level of residual contents and the presence of materials that were never intended for food contact. Certifying the sorting step turns that history from an assumption into a record.

Digital Product Passport and Blockchain

The RecyClass roadmap for 2026-2028 includes digitalising certificates, blockchain-based transaction records and integration with the Digital Product Passport (DPP). The aim is to increase traceability in a regulation-driven market while reducing administrative load. In practice this means that within a few years the history of an rPET batch will travel with it in machine-readable form.

How This Shows Up in a Supplier Audit

The shift is easiest to see in what an audit now asks for. A few years ago, presenting a valid certificate was usually enough to close the topic. Today an auditor is more likely to pick a delivery from the past twelve months and work backwards from it: which batch was it, which process produced it, what did the input look like that week, and do the numbers in the certificate of analysis match the numbers in the production records?

That kind of question can only be answered by a supplier whose records were built to be read backwards. It is a different discipline from collecting certificates, and it is the reason documentation is becoming a purchasing criterion in its own right rather than a formality handled after the commercial terms are agreed.

The Practical Consequence for Brand Owners

These three developments point the same way: the data behind a certificate is becoming as important as the certificate itself. For a brand selling into the EU market, the questions asked during supplier assessment are changing:

• Is the production process EFSA-authorised, and can the registration number be shared?
• Can the sorting process on the input side be documented?
• Are purity, colour and contamination figures reported batch by batch?
• Is the supplier ready for digital traceability infrastructure such as the DPP?

A supply chain that cannot answer these questions today will struggle with the minimum recycled-content rates coming into force in 2030.

The Timeline to Keep in View

Three dates frame the next few years. The 2022/1616 amendment was notified to the WTO in April 2026 and is expected to be adopted by the end of September 2026. The PPWR has applied since 12 August 2026, moving recycled content from a voluntary claim to a regulated requirement. And 2030 brings the minimum recycled-content thresholds that every packaging decision taken today is effectively being designed against. Supplier qualification takes months; contracts signed now are the ones that will be audited against those thresholds.

Supply Is Growing on the Turkish Side

This tightening on the demand side coincides with growth in Turkey’s collection infrastructure. The deposit return system (DOA), rolled out across all 81 provinces on 1 July 2026, had channelled more than 100 million beverage containers into recovery by 11 August; roughly two thirds of what was collected were PET bottles. PET arriving through a deposit system is a markedly cleaner and more traceable input than material picked out of mixed waste.

The difference is not only about cleanliness. Material that enters through a deposit system carries a known route from the return point onwards, which is precisely the kind of input history the new sorting certification is designed to capture. A cleaner bale reduces processing losses; a documented bale makes the resulting batch defensible in front of an auditor.

So while the EU’s demand for documentation rises, the supply of raw material capable of carrying that documentation is growing in Turkey. For food-grade rPET granules and high-purity PET flakes, the intersection of these two curves opens a significant window for producers that have completed their certification.

What to Put in Your Next Tender

If you are preparing a purchasing specification for 2027 volumes, four requirements cost nothing to add now and are expensive to retrofit later: the process registration reference stated on every declaration of compliance; batch-level analysis reports issued as a matter of course rather than on request; documented input origin for the material class you are buying; and a written commitment that the supplier will support digital traceability formats as they become mandatory. Suppliers that already work this way will not object to any of the four.

Sources:
EU Proposes Amendments to Regulation (EU) 2022/1616 — REACH24H
RecyClass launches certification for plastic sorting processes
RecyClass Roadmap 2026-2028
New EU rules on packaging enter into application — European Commission
DOA system passes 100 million containers