Certification of recycled material in food-contact packaging.

Packaging intended for contact with food in accordance with Regulation 2022/1616 and the PPWR.

‘Food-contact’ is the proverbial ‘Holy Grail’ in recycled material certification. Those who have it can sell at a higher price, take part in tenders and include a statement on their website that their competitors cannot. Those who do not have it end up selling flakes for the production of buckets. The difference is far from trivial. “Suitable for food contact” means that the material has undergone a process which confirms that no substances capable of contaminating food migrate from it, and that the entire chain (from waste, through recycling, to regranulate) is traceable and controlled at every stage.

What RecyClass with the food-contact module does not do (and why this is not a problem)

A RecyClass certificate with the A1 or A2 Food-contact module does not relieve the certified organisation of any legal obligations. Authorisation of the decontamination process, entry in the EU register, declaration of conformity in accordance with Regulation (EU) 2022/1616, technical documentation and the EU declaration of conformity under the PPWR… all of this remains exactly where it was. That is, with the party to whom it applies.

The certificate confirms that an independent body has verified compliance with the relevant obligations. It indicates that appropriate procedures are in place, records are accurate, and the traceability system is effective. It does not constitute ‘approval for food contact’.

Why is it still worth having?

It is a matter of credibility and of being able to join existing chains that systemically require this module. A converter already certified with A2 will not accept flakes without proof of origin. The certificate is the tool that legitimises the claims made in communication and trade. The rest of this article is about how not to lose it along the way.

Mass balance has entered the law… but food contact only begins beyond it

Commission Implementing Decision (EU) 2026/1425 of 30 June 2026 sets out how recycled content in PET bottles is to be calculated and verified under the SUPD (Single Use Plastics Directive).

• For mechanical recycling it relies on the system of Regulation 2022/1616.
• For chemical recycling, it introduces mass balance at plant level. Fuels and losses are excluded. Volumes cannot be transferred between plants. Third-party certification is required. Certificates are passed down the chain as far as the filler.

This approach has been used in ISCC PLUS for many years. RecyClass also accepts recyclate from chemical recycling, provided that mass balance rules can be applied to it. This means that here, too, the route to counting recycled content remains open.

Mass balance doesn’t tell the whole story

However, mass balance determines how much recyclate has been attributed to a given bottle; it does not determine whether that bottle may be intended for contact with food. The technology must be recognised as “suitable”, i.e. listed in Annex I, or be authorised as a novel technology. In the latter case the process requirements must also be met, including a Commission decision, a RIN (Recycling Installation Number) and a CMSS (Compliance Monitoring Summary Sheet).

For chemical recycling intended for food-contact applications, this applies in particular to depolymerisation, pyrolysis and the use of recyclate behind a functional barrier. In many cases, these technologies are still classified as novel technologies and remain under assessment. They therefore cannot currently be covered automatically by Food Contact Module A2.

Applying mass balance rules and holding the resulting certificate does not replace the requirements of Regulation 2022/1616. It does not, on its own, provide a basis for treating a material as suitable for food contact. Plans to count chemically recycled content towards the 2030 thresholds in Article 7 of the PPWR should therefore be approached with caution. The circular origin of the material is relatively easy to document. Its acceptance for food-contact use requires a separate route and additional documentation. It also takes time to complete this process.

RecyClass as a model for the food-contact supply chain

In what follows, we walk through the regulatory and practical background. We use the RecyClass certification scheme as an example. It is one of the few schemes with a dedicated module that allows a systematic approach to materials intended for food contact.

RecyClass distinguishes two levels of food-contact modules

1. Sorting Process + Moduł Alpha

Let us start the journey at the source: the sorting facility. RecyClass has a separate Sorting Process Certification scheme for sorting facilities and subsequent waste-trading operators, with Module Alpha for streams intended for food-contact recycling (version 1.0, October 2025).

As of today, the Sorting Process and Module Alpha are not mandatory. This applies both under the law and as a requirement of the next link in Modules A1/A2. They are, however, useful. The key condition for material to be “intended for food contact” is that the recycler demonstrates compliance with Article 6 of Regulation 2022/1616. This includes municipal origin, separate collection, sourcing from a country with equivalent legislation, and batch traceability. The supplier must also operate an effective quality-assurance system for collection and sorting. How the recycler demonstrates compliance is up to the recycler.

There are two routes:

• Without a sorting certificate: the recycler documents all of the above itself: it collects supplier declarations on origin and method of collection, purchase specifications requiring separate collection, publicly available information about the collection system (e.g. a DRS description: accepted stream, return route, exclusion of the residual fraction), and maintains a supplier-approval procedure and incoming inspection. The auditor checks whether the collection route and accepted items have been verified and whether supplier control is part of the system rather than a set of supplier statements. This works, but it has to be repeated for every supplier, every year, and the recycler carries the effort and the risk.
• With a sorting certificate (Sorting Process + Module Alpha): the proof is ready: the sorting facility has itself been audited for origin, separate collection and traceability, and the recycler shows the certificate instead of building the documentation from scratch. This shortens the process.

Module Alpha is therefore a tool for demonstrating compliance with 2022/1616 at a stage that nobody had certified before within RecyClass. It can be treated much like ISO 9001 at a supplier: nobody strictly requires it, but without it every audit starts from zero for the recycler. Its real value at the next link appears when there is a trader or several sorting facilities in the chain: collecting and verifying declarations then stops being feasible within a reasonable time.

Module Alpha under RecyClass Sorting Process can be applied for both by a sorting facility and by a waste trader.

2. RecyClass Recycling Process + Food Contact Modules A1 and A2

Since 10 October 2024, Regulation 2022/1616 requires certification of the quality-assurance and traceability system for pre-processing operations from the first point of sorting, which is why every applicant with plastic input intended for food-contact recycling under Recycling Process is required to apply for Module A1. Within RecyClass this module cannot be skipped when certifying material intended for contact with food; in this configuration it is mandatory. But let us take it step by step. RecyClass distinguishes two levels of certification for materials qualifying for contact with food:

Module A1 (pre-processing)

→ covers preliminary operations (sorting, shredding, washing, mixing) that prepare the waste for subsequent decontamination, ensuring traceability of the input waste and compliance with Article 6(3) of Regulation 2022/1616.

Module A2 (decontamination)

→ covers decontamination processes that transform plastic input into recycled plastic suitable for food contact. Four entry conditions must be met together:

1. the process must use a suitable technology listed in Annex I, Table 1 of 2022/1616;
2. all plastic input must come from suppliers certified under Module A1;
3. a CMSS positively audited by the competent authority must be in place;
4. the organisation holds a Commission authorisation decision and the RAN, RON, RIN and RSN numbers.

Module A2 may be issued to organisations anywhere in the world, provided the above conditions are met. The only geographical restriction concerns novel technology.

A single certificate may cover both modules, with the scope divided by product. Flakes produced after the preliminary cleaning process are certified under Module A1. Regranulate produced after decontamination is certified as a PRODUCT under Module A2. This is what a typical audit report for a PET recycler looks like when the facility has both a shredding/pre-treatment line and a decontamination line.

3. RecyClass Recycled Plastics Traceability +Food Contact Module A2

Let’s assume that a converter holds a RecyClass Recycled Plastics Traceability certificate and purchases material from a recycler with Module A1. A question we are often asked is:

“Is this already a food-contact chain?”

The answer, however, is simple:

“No!”

From A1 via A2 to Traceability: where does the A2 level sit for a converter or salesperson?

It is important to distinguish between the two schemes. The RecyClass Recycling Process (recycler) and the RecyClass Recycled Plastics Traceability (converter, compounder, trader, manufacturer) are separate stages and certifications.

• The Recycling Process certificate is recognised as a supplier certificate within the Recycled Plastics Traceability scheme.
• The Traceability scheme assesses requirements at two levels:
  • Level 1 mandatory)
  • Level 2 (optional)

and may be supplemented by additional modules. For food-contact applications, this is always Module A2 (there is no equivalent to A1 as with the recycler).

We present the whole process in a block diagram:

Two relevant rules

The key rule is that the output from Module A1 is input material for decontamination, not ‘food-contact’ recycled material. After sorting, grinding and washing at a recycler certified under Module A1, the flakes have not undergone a decontamination process. The converter therefore cannot accept them as food-contact recycled material. Decontamination must take place prior to the converter, i.e. at a recycler holding EC authorisation, a RIN and a declaration of conformity in accordance with Annex III to Regulation (EU) 2022/1616. Alternatively, it may take place at the converter’s premises, provided they have their own decontamination facility, their own authorisation, a RIN and CMSS. This is crucial and is the source of the most common non-conformities identified during audits.

The second rule, more often ignored: food-contact continuity does not end at the recycler; it continues in Traceability, and under the food-contact module it always appears as A2 (reminder: the A1/A2 split exists only in Recycling Process). Every organisation certified under Traceability (converter, compounder, trader, filler) receives Module A2, because from its perspective only one thing matters: whether it handles decontaminated recyclate and maintains its traceability. A converter that receives decontaminated recyclate and declares it in food-contact products must have Module A2 on its own Traceability certificate, regardless of whether it decontaminates itself. The supplier’s certificate and the DoC are necessary but not sufficient, because without Module A2 on the converter’s side the food-contact traceability chain breaks at that link. Products listed in the certificate annex are assigned Module A2 only where they can carry a food-contact claim “after” the recyclate.

The sequence is therefore always the same: demonstrated origin at the sorting stage (Alpha, or declarations + collection system) → A1 (pre-processing) → A2 (decontamination, Recycling Process) → A2 (Traceability, every subsequent operator declaring food contact).

You can reduce the number of entities, but never the number of stages. Nor can you ‘lose’ the A2 along the way. If there is even one traceability certificate in your chain without an A2 between decontamination and the bottling plant, there is no food-contact chain.

The PPWR and DoC context

Two different declarations of conformity operate in a food-contact chain with recyclate, and they should not be confused.

• Declaration of compliance under Annex III to Regulation 2022/161; issued by the decontamination plant for each batch of recyclate; this is the one that answers the question of food-contact safety (Regulation 1935/2004).
• The EU declaration of conformity under the PPWR (Annex VIII); issued by the packaging manufacturer; it answers the question whether the packaging meets the PPWR requirements, including the minimum recycled content under Article 7.

How does certification with Module A1 or A2 function in this context?

Module A1 independently confirms that the waste meets the Article 6 criteria of Regulation 2022/1616. These include municipal origin, separate collection, a country with equivalent legislation, batch traceability and a quality system at the supplier. For the decontamination plant, this provides ready-made evidence that the A2 input requirements and Article 6(3) are met. For the PPWR, it provides evidence that the recyclate is post-consumer. Only post-consumer recyclate counts towards the Article 7 thresholds. The Commission guidance requires the manufacturer to document this in the technical documentation. A declaration alone is not sufficient.

Module A2 is the basis for treating the material as food-contact recyclate for the converter. It also provides the basis for calculating its share in the product under the controlled-blending model. For the packaging manufacturer, it provides two elements of the Annex VII technical documentation. First, it provides the recycled-content calculation with a traceable source. Second, it provides evidence that the food-contact compliance of the recyclate is addressed under the 2022/1616 regime, rather than based solely on a supplier’s statement.

Technical documentation for packaging with food-contact recyclate that rests solely on supplier statements, without a certificate carrying Module A1 or A2, is a declaration without evidence.

Novel technology: what it is and where it sits in certification?

Both routes (RecyClass and the SUPD) refer back to Regulation (EU) 2022/1616, Article 3(6): “Any recycling technology that has not been subject to a decision on its suitability in accordance with Article 15 or 16 shall be regarded as a novel technology for the purpose of this Regulation.”

A novel technology is therefore any recycling technology on which the Commission has not taken a decision on its “suitability”.

It is a formal-administrative criterion. Its opposite is a suitable recycling technology listed in Annex I, Table 1 (in practice today: mechanical recycling of PET and recycling in closed and controlled product loops). Everything else (pyrolysis, depolymerisation, dissolution, mechanical recycling of polyolefins into food-contact materials) currently has novel-technology status.

Novel technology vs. A1 and A2 Modules

The possibility of such a process demonstrating compliance with Food Contact Modules A1 and A2 differs from mechanical recycling:

• A1:certification is possible provided the plastic-input requirements are met in the same way as for mechanical technology, i.e. all suppliers must hold a valid A1 certificate, and so must the organisation’s own pre-processing.
• A2: certification is not possible; A2 is issued only for suitable technologies listed in Annex I, so a decontamination plant using a novel technology does not meet this formal condition.

Further implications of novel technology

A further restriction concerns the very possibility of certifying a novel technology under the general scope (the so-called General module). A certificate for the general requirements (Recycling Process or Traceability) is possible only within the EU27+3. Outside that area, certification of a novel technology for food contact is not possible – the only geographical restriction in the whole of RecyClass.

A recycler outside the EU27+3: what the real restriction is?

EU law does not close the door to third-country recyclers; it holds them to the same requirements as EU operators. Installations outside the EU must fully comply with 2022/1616 if their recyclate reaches the European market. The Union register under Article 24 keeps a separate list of RIN numbers for installations located outside the EU. The RecyClass scheme follows the same track. Food Contact Module A2 may be issued to organisations anywhere in the world, provided the technology is suitable, 100% of inputs come from Food Contact Module A1 and the CMSS has been audited.

The real restrictions for a recycler outside the EU27+3 are therefore three:

1. Module C (Corporate Social Responsibility – CSR);
2. A legal-equivalence report for the country where the waste is collected (see below);
3. No transitional exemption for the certification of inputs: 100% from day one. Informal collection systems are excluded.

These are described below.

Waste origin and equivalence of national law

For a material to be eligible for recycling as food-contact plastic, three key criteria must be verified. These are based on the RecyClass guidelines and reflect the requirements of Article 6 of Regulation (EU) 2022/1616:

1. Where the waste comes from geographically

The auditor must establish whether the waste originates from the EU27, Iceland, Liechtenstein, Norway, Switzerland or the United Kingdom. If it comes from outside this area, the report must describe the verified equivalence evidence rather than assume compliance.

NOTE: this is a different set from the “EU27+3” used for Module C (CSR); for waste origin what matters is the area in which Regulation 10/2011 or its recognised equivalent applies.

2. Equivalence of the law of the country of collection

If the waste was collected outside that area, it must be shown that the country of collection has legislation equivalent to Regulation (EU) No 10/2011 (including a positive list of substances for the manufacture of food-contact plastics) and the equivalence evidence must be provided to the certification body at audit. If the third country permits food-contact recyclate, equivalence must also cover 2022/1616. In audit practice this evidence is a report by an independent law firm, approved by the national food-safety authority, separately for each country of origin. Chemical analysis of the output does not replace the report and is not audit evidence.

3. How the waste was collected.

The waste must originate from municipal or equivalent waste and from a separate collection system that keeps plastics apart from the residual fraction or from private separate-collection projects (door-to-door, DRS, drop-off points). Excluded are non-separate systems (hand-picking, ocean waste) and mixed waste, including co-mingled waste post-sorted at a sorting centre. In addition, the waste must be identifiable in the stock area per batch, with batch-to-batch traceability maintained throughout the process.

Table: Food-contact chain configurations in RecyClass certification

The most frequent non-conformities(from the auditor’s practice)

Four factors are responsible for the majority of delays in food-contact certification. Interestingly, none of them are technological:

1. Certified supplies do not cover the period.
   The auditor assesses a period, not the state on the audit date: at initial certification at least 3 months of documented supplies covered by A1/A2 (Provisional certification); in subsequent years a full 12 months.
2. A broken A2 in the chain.
   A supplier without Module A, a converter declaring food contact from A1 flakes, or — most often — a link with a Traceability certificate without A2 between decontamination and the filler. On every certificate in turn, check the module, the level (A1 or A2) and the assignment of the module to the products in the annex.
3. Critical conditions overlooked at application stage.
   Lack of a waste permit is a critical non-conformity in Recycling Process; an operator that only decontaminates and buys flakes applies for Traceability + A2, not for Recycling Process. This must be settled at the application stage.
4. The equivalence report and inputs from outside the scheme.
   The equivalence report must come from an independent law firm and be approved by the national food-safety authority, separately for each country of origin.

Wnioski praktyczne na temat food-contact

The food-contact regime is not simply a stricter version of ordinary recyclate certification. It is a separate chain of evidence. That chain starts at the sorting facility, not at the recycler. Building a properly certified food-contact chain with a recycler is comparatively formalised. With a recycler outside the EU+3, the process is in practice more uncertain, longer and several times more costly than an equivalent chain within the EU+3.

One point follows from our audit practice and is worth stating plainly:

for recyclers outside the EU+3, the problem is not necessarily the sophistication of the technology. We see plants that have everything: a modern installation, Commission authorisation, RIN and RON numbers, an audited CMSS and full batch traceability. Yet they fail on two issues: waste origin and the collection system. The waste must come from a country with legislation equivalent to Regulation 10/2011. It must also come from separate municipal collection. It cannot come from hand-picking or from a mixed stream that was later sorted at a sorting centre. If the country of collection has no positive list of substances and no credible separate-collection system, no technology can compensate for this. And this happens often.

These barriers are not an invention of RecyClass. They follow directly from Article 6 of Regulation 2022/1616 and from Regulation 10/2011. The certification scheme merely checks whether these requirements have been met. This is why the first question about a chain involving a recycler outside the EU+3 should not be “what technology does it have?”, but rather “where does it get its waste, and who will confirm it?”.

Next step

Silk Road Certification carries out certification of the food-contact chain, covering the following stages: Module Alpha in the RecyClass Sorting Process, Modules A1 and A2 in the RecyClass Recycling Process, and Module A2 in the RecyClass Recycled Plastics Traceability scheme.

We have experience in certifying organisations in the EU and Turkey, including those covered by Module A1, Module A2 or both modules.

Silk Road Certification is a PCA-accredited certification body for RecyClass in the areas of Traceability and the Recycling Process. Accreditation was granted on 19 December 2025.

We look forward to working with you!