SG 167/25
European Union (EU) corrects several errors in its regulation on recycled materials and articles intended to come into contact with food.
In 2022, the EU issued Regulation (EU) 2022/1616, establishing a framework for placing food contact recycled plastics on the market (‘the Regulation’, SafeGuardS 114/22).
Key provisions in the Regulation include, but are not limited to:
- Introducing rules for the use of suitable recycling technologies for recycling waste into food contact plastics that comply with Article 3 ‘General requirements’ under Regulation (EC) No 1935/2004 (current consolidated version to March 2021) and are microbiologically safe
- Setting requirements on the development and use of recycling technologies
- Detailing the procedure for the authorization of individual recycling processes
- Establishing an EU register for novel technologies, recyclers, recycling processes, recycling schemes and decontamination installations
- Specifying requirements for waste management operators
The Regulation has applied since October 2022, but several errors have been identified since its implementation.
On November 13, 2025, the EU issued Commission Regulation (EU) 2025/2269 to correct the Regulation regarding the labeling of recycled plastic, the development of recycling technologies and the transfer of authorizations. These corrections clarify, among other things, the clauses and the economic operator concerned with the implementation of specified provisions in the Regulation.
A comparison of several changes between the Regulation and the new law are detailed in Table 1.
| Regulation (EU) 2025/2269 correcting the Regulation | Regulation (EU) 2022/1616 (the Regulation) | |
|---|---|---|
| Article 4 ‘Requirements for recycled plastic materials and articles’ Point 1 |
Recycled plastic materials and articles shall only be placed on the market where the requirements set out in points 2 to 8 are met during their manufacture | Recycled plastic materials and articles shall only be placed on the market where the requirements set out in points 2 to 7 are met during their manufacture |
| Article 5 ‘Requirements for documentation, instructions and labeling’ Point 3, first sentence |
Recycled plastic delivered to converters shall bear the label affixed to each container showing the symbol defined in Annex II to Regulation (EC) No 1935/2004, followed by: | Containers of recycled plastic delivered to converters shall be labeled. The label shall show the symbol defined in Annex II to Regulation (EC) No 1935/2004, followed by: |
| Article 10 ‘Requirements for the development of novel technology’, Point 4, first sentence |
At the time of the notification, the developer shall also publish a detailed initial report on its website using the URL provided in accordance with paragraph 2, concerning the safety of the manufactured plastic based on the information provided in paragraph 3 | At the time of the notification, the recycler shall also publish a detailed initial report on its website using the URL provided in accordance with paragraph 2, concerning the safety of the manufactured plastic based on the information provided in paragraph 3 |
| Article 22 ‘Request for the modification of an authorization by the Authorization holder’ Point 4, first sentence |
In case the modification concerns a transfer of the authorization of a recycling process to a third party, the current authorization holder of the authorized process shall notify the Commission by registered letter before the transfer, indicating the name, address and contact information of that third party | In case the modification concerns a transfer of the authorization of a recycling process to a third party, the authorization holder shall notify the Commission before the transfer, indicating the name, address and contact information of that third party |
Table 1
Regulation (EU) 2025/2269 will enter into force on December 3, 2025 – 20 days following its publication in the Official Journal of the EU.
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