Global Food Contact Materials Regulations

This module will look at the regulations that exist currently on recycled plastic materials intended for use in food contact applications in the following key markets: the EU, UK (after Brexit), Switzerland, US, Mercosur, Japan, South Korea and India.

A particular focus will be given to the new EU regulation on recycled plastic FMCs i.e., Regulation (EU) No 2022/1616, which fully replaced the previous Regulation (EC) No 282/2008. 

As per the new EU regulation, new terms such as suitable and novel recycling technologies will be introduced and the associated regulatory requirements will be discussed in direct connection with an EU authorization on the recycling processes. 

The registration forms for recycling installations, recycling facilities, recycling companies, recycling schemes and novel recycling technologies will be presented and discussed, as well as the Union Register created by the European Commission until 18 July 2023 will be presented.  

During this module, you will learn about:

• the new requirements for recycled plastics intended for use in the EU in food contact applications, considering Regulation (EU) No 2022/1616;
• the requirements that apply for recycled plastic materials intended for use in food contact applications in the US; the US FDA Guidance for industry: use of recycled plastics in food packaging will be presented and discussed;
• the acceptance criteria for recycled polyethylene terephthalate (PET) resin intended for use in food contact applications in India and the guidelines for the recycling process;
• the requirements of Mercosur GMC Resolutions 25/99 and 30/07 on PCR-PET intended for use in food contact applications in Mercosur;
• the restrictions/requirements that apply to post-consumer recycled (PCR) plastics intended for use in FCMs in Japan will be presented;
• the tests (e.g., challenge tests, migration tests) to be considered, with case study examples;
• the analytical challenges in identifying non-intentionally added substances (Nias) that migrate from PCR plastics into food, considering the intended conditions of use;
• key steps for obtaining authorisation on the recycling technology/process in the EU and US; and,
• how to demonstrate compliance of recycled plastic materials intended for use in food contact applications in the above mentioned markets.

Ioan Paraschiv, PhD

Group Leader, Global Food & Food Contact Materials (FFCM) Division, Knoell, Netherlands