What is it about?
EU Regulation 2022/1616 sets out how plastics may be recycled if they are to come into contact with food again at a later stage.
It is intended to ensure that recycled materials do not contain any substances harmful to health.
For the flexible packaging industry (films, bags, laminates), this regulation has very specific implications.
First things first1. First things first
Not all recycled materials are suitable for use in food packaging.
The key factor is not whether a material is “recycled”, but rather:
- how it was recycled
- which method was used
- where the waste material comes from
What is currently allowed – and what isn’t?
✅ Permitted (as of April 2026)
1. Mechanical PET recycling
- Applies only to PET
- The recycling process must:
- assessed by the EFSA
- and be registered throughout the EU
- Works particularly well for:
- bottles
- plain PET film (single-material)
This means it can generally be used for PET-based flexible packaging, provided it is sorted by type.
2. Recycling in closed and controlled cycles
- The material comes from defined, monitored systems
- Examples:
- production leftovers
- Return schemes
- B2B cycles
- Advantage:
- hardly any foreign substances
- low risk of contamination
These sources are particularly interesting for film manufacturers, but they are organisationally challenging.
❌ Not permitted (for food contact)
- Mechanically recycled PE or PP films from household waste
- Multilayer recycled materials from open collection systems
- Recycled materials without proven decontamination performance
These materials must not be used for food packaging.
Why does this affect flexible packaging in particular?3. Why does this affect flexible packaging in particular?
Flexible packaging has three structural drawbacks:
- Many material combinations
Composites are difficult to assess definitively - Large surface area
greater exposure to potential contaminants - Unregulated material flows
Origin and previous use often unknown
The Regulation assumes that:
If you don’t know exactly what was in the plastic before and how it’s made, you shouldn’t simply reuse it for food.
Chemical recycling – a ray of hope, but not yet a solution4. Chemical recycling – a ray of hope, but not yet a solution
Chemical recycling is mentioned in the Regulation, but:
- not yet approved for general use
- permitted only as “new technology” under observation
Chemical recycling is particularly strategically important for flexible packaging, but there is as yet no general regulatory approval.
What does this mean in practical terms for the industry?5. What does this mean in practical terms for the industry?
- ✅ PET continues to grow in importance
- ✅ Design for recycling is a requirement, not an option
- ❌ PE/PP PCR testing for food remains severely restricted❌ PE/PP‑PCR für Food bleibt stark eingeschränkt
In future, companies must be able to answer
- Where does the recycled material come from?
- Which method was used?
- Has the process been approved and registered?
Strategic implications for manufacturers of flexible packaging
The regulation clearly steers the industry in the direction of:
- fewer materials
- simpler structures
- controlled cycles
- Early coordination between design, recycling and regulation
Recyclability is becoming a regulatory requirement, not just a sustainability claim.
Fazit
EU Regulation 2022/1616 is not a ban on recycling, but a clear market selection:
Only recycled materials from processes that have been verified as safe may be used in flexible food packaging.
