Food-grade rPET is the recycled polymer with a working, regulated route back into direct food contact, and the EU controls that route tightly: recycled plastic may only be placed on the market if it comes from an authorised recycling process. The rPET food contact approval in the EU framework therefore decides which pellets can legally become bottles, trays and films, and buyers who skip the paperwork question end up with material they cannot document. This guide explains who authorises what, what EFSA actually evaluates, and what a buyer should require from an rPET supplier.
The Legal Base: Regulation 2022/1616
Recycled plastics in food contact are governed by Commission Regulation (EU) 2022/1616, which replaced Regulation (EC) 282/2008 in October 2022. Its central rule is simple: no recycled plastic material may be placed on the EU market unless the recycling process that produced it has been authorised. Applications go through the E-Submission Food Chain Platform to a Member State competent authority, which forwards the dossier to EFSA; EFSA delivers a scientific opinion on the process, and the European Commission issues the authorisation. Each authorised process carries an EU register number, and the list of authorised processes is public.
What EFSA Evaluates: Decontamination, Not the Plant
EFSA's assessment centres on a challenge test: the applicant demonstrates that the process removes deliberately added surrogate contaminants to a level that does not pose a health risk. The Panel identifies the critical steps that determine decontamination efficiency, typically combinations of temperature, pressure, residence time and gas velocity in reactors, extruders or solid-state polycondensation stages, and the EFSA authorisation then requires the plant to operate at least as severely as those conditions. Input rules matter as much: authorised PET processes accept washed, dried post-consumer PET flakes from food-contact articles, with no more than 5% PET from non-food consumer applications, and periodic verification of input composition is part of the deal.
What an Authorisation Covers, and What It Excludes
Authorisations are process-specific and condition-specific. Typical conditions allow the recycled PET to be used at up to 100% for articles in contact with all types of foodstuffs, including drinking water, for long-term storage at room temperature, with or without hotfill, while microwave and conventional oven use stays outside the scope. Those conditions flow into the declaration of compliance for the finished article, which sits on top of the general food-contact framework in Regulation (EC) 1935/2004 and Regulation (EU) 10/2011. The practical consequence: an rPET pellet is not food grade in the abstract; it is food grade for the conditions its process authorisation covers.
How rPET Food Contact Approval in the EU Differs for Other Polymers
Almost all authorised food-contact recycling processes are PET processes, because the polymer's collection streams are clean and its decontamination technologies are proven. Food-grade rHDPE and rPP remain scarce, and recyclate from mixed polyolefin streams is normally limited to non-food applications. Because the recycled plastic food contact rules attach to the process rather than the reseller, a trader's own certificate is no substitute for the process authorisation. Buyers specifying rPE or rPP for food contact should expect to justify the application rather than assume an authorisation exists.
The Demand Pull: PPWR Recycled Content Targets
Regulation (EU) 2025/40 adds commercial pressure: from 2030, plastic packaging placed on the EU market must meet minimum post-consumer recycled content, including 30% for single-use PET beverage bottles and contact-sensitive PET packaging, 10% for other contact-sensitive packaging and 35% for other plastic packaging, assessed per plant per year. Packaging is exempt where recycled content would compromise compliance with Regulation 1935/2004, which is why the authorised-process route is the bottleneck for food-grade ambitions. The safety rule and the content target only work together when the recyclate can be documented.
What Buyers Should Require from an rPET Supplier
- The EU register number or authorisation reference for the recycling process, plus confirmation the plant operates within the authorised conditions.
- A declaration of compliance that references the authorised process and covers the intended food-contact use.
- Batch traceability from pellet back to the authorised process, with migration testing for the finished article.
- Input traceability showing the feedstock stayed within the authorised composition limits.
- For non-PET polymers, explicit evidence that a food-contact authorisation exists at all.
For the wider framework, our guides to EU food contact regulation 10/2011, FDA food contact compliance, PCR grades and recycled content targets cover the compliance landscape around the recycling decision.
Related product categories
The materials and part types discussed above are grouped in our sourcing directory:
