The European Union has issued targeted corrections to its main regulation governing recycled plastics used in food contact materials. The move aims to remove ambiguities, clarify responsibilities, and ensure smoother compliance for recyclers, converters, and other operators across the packaging supply chain.
Table of Contents
Background: Why the Regulation (EU) 2022/1616 Needed Corrections
In 2022, the EU released Regulation (EU) 2022/1616, a broad framework controlling how recycled plastics can be placed on the market for food contact. Key elements of the original regulation include:
- Rules for using suitable recycling technologies that meet Article 3 of Regulation (EC) No 1935/2004 and ensure microbiological safety
- Requirements for developing and using recycling technologies
- Procedures for the authorization of recycling processes
- Establishment of an EU register for novel technologies, recyclers, recycling processes, schemes, and decontamination installations
- Specific obligations for waste management operators
Since its implementation on October 2022, several technical and drafting errors have been identified. These issues created uncertainty for companies navigating documentation, labeling, technology development and authorization transfers. To correct them, the EU adopted Commission Regulation (EU) 2025/2269 on November 13, 2025.
Labeling Requirements Made Clearer
The correction tightens the rules for labeling recycled plastic delivered to converters. The revised text now states that each container must bear a label showing the symbol defined in Annex II of Regulation (EC) No 1935/2004. The earlier wording lacked clarity on:
- Whether labeling applied to all containers
- How explicitly the symbol must be displayed
Clarifying Who Publishes Technology Reports
Article 10, covering the development of novel technologies, now makes clear that:
- The developer, and not the recycler, must publish the detailed initial report on its website
- The report must cover safety information listed under paragraph 3
- The URL provided under paragraph 2 must be used
This correction is important since developers and recyclers are often separate organizations.
Fixing Requirements for Authorization Transfers
Regulation (EU) 2025/2269 also refines the procedure for transferring an authorization for a recycling process to a third party. The correction confirms that the “current authorization holder of the authorized process” must notify the Commission before any transfer, and that the notice must include the third party’s contact details, since the original text did not clearly specify which operator had this responsibility.
Expanded Requirements for Placing Materials on the Market
Under Article 4, the corrections adjust the list of requirements that must be met before recycled plastic materials and articles can be placed on the market. The updated regulation now refers to points 2 to 8, instead of 2 to 7. This ensures all intended conditions are captured.
Conclusion
Regulation (EU) 2025/2269 has entered into force on December 3, 2025, twenty days after publication in the Official Journal. Packaging and recycling industry stakeholders should review the updated text to ensure their processes, documentation and responsibilities match the clarified requirements. The corrections are narrow but meaningful, and they close gaps that previously made compliance more complicated than intended.
