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EU Publishes Corrections to Regulation on Recycled Plastic Food Contact Materials

The amendment refines labeling duties, responsibility for safety reports, confidentiality rules, and authorization transfer procedures.

On November 13, 2025, the European Commission published Commission Regulation (EU) 2025/2269. This regulation explicitly corrects provisions in Regulation (EU) 2022/1616 regarding the labeling of recycled plastic, the development of recycling technologies, and the transfer of authorizations for materials intended to come into contact with food.

Key Regulatory Changes

The corrections include specific clarifications affecting recyclers and developers as follows: 

  • Labeling Requirements: Article 5(3) is amended to clarify that labeling obligations apply to the recycled plastic delivered to converters. The previous text ambiguously suggested the requirements might apply to the composition of the containers transporting the plastic.

  • Responsibility for Safety Reports: Article 10(4) now correctly assigns the obligation to publish the initial safety report to the developer of the novel technology. The original text incorrectly placed this burden on the recycler.

  • Confidentiality: The regulation clarifies that the summary of novel technology and block diagrams of manufacturing sequences cannot be treated as confidential. 

Compliance Procedures and Timelines

The update also formalizes administrative procedures. Under the corrected Article 22(4), if an authorization holder transfers an authorization to a third party, they must notify the Commission specifically by registered letter. This adds a procedural requirement that was previously omitted.

Implementation

Commission Regulation (EU) 2025/2269 will enter into force on December 3, 2025, twenty days following its publication in the Official Journal. Industry operators should review their current documentation and reporting procedures to ensure alignment with these clarified provisions.

Tags : EUFCM
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