Recycled plastic, paper, and board in food contact materials – overview of regulations

The European Union is eager to increase the production of recycled food contact materials (FCMs) as a part of its Circular Economy Action Plan and the new Packaging and Packaging Waste Regulation (PPWR). To further this goal without compromising consumer safety, legislation is actively reformed, as is evident from several recent regulations. Most notably, Regulation (EU) 2022/1616 established the basic framework for using recycled plastic in food contact materials, with clarifications to purity requirements later introduced by Regulation (EU) 2025/351.

For materials other than plastic, similar harmonized EU-level legislation does not yet exist. Still, it is possible to use recycled paper and board in FCMs under Member States' national provisions, as long as an extended safety assessment is performed to counter the increased risks of harmful substances forming and migrating into food when the material is reprocessed.

General requirements for food contact material safety

All food contact materials manufactured and sold in the EU – including recycled ones – are subject to the Framework Regulation (EC) 1935/2004 and the GMP Regulation (EC) 2023/2006, which establish the general principles for material safety and good manufacturing practices.

According to the framework regulation, all FCMs must be sufficiently inert not to transfer chemicals into food in quantities that could endanger human health, cause inappropriate changes in composition, or diminish sensory properties.¹ In practice, inertness is evaluated through substance-specific migration or concentration limits, in addition to which an overall migration limit applies to plastic FCMs.

For some materials, migration limits are defined in material-specific EU regulations, such as the Plastics Regulation (EU) 10/2011. When dedicated regulations do not exist – as is the case with paper and cardboard – the transfer of harmful substances from both virgin and recycled materials must be evaluated primarily based on national legislation and recommendations.

Requirements for recycled plastic in food contact materials

The Recycled Plastic Regulation (EU) 2022/1616² sets clearer rules than before on the kinds of recycled plastic materials that can be used in FCMs. A key part of the regulation is a list of approved recycling techniques, found in Annex I of the document. 

Currently, just two recycling technologies have been approved for the production of recycled plastic FCMs: mechanical recycling of food-grade, separately collected post-consumer PET and closed product loop recycling of food-grade plastic that is cleaned and reprocessed for the same purpose for which it was originally intended. After the transition period that ended in July 2023, recycled plastic obtained through unauthorized techniques can no longer be used in food contact applications.

Additional recycling methods may be added to the list in the future. For a technique to be approved, its developer has to demonstrate to the European Food Safety Authority (EFSA) that the plastic obtained is chemically and microbiologically safe. The process is demanding and time-consuming, but in principle, even mixed household plastic waste streams could be used if appropriate recycling and waste collection processes are developed. Before Regulation (EU) 2022/1616, only separately collected PET could be authorised, and mixed household plastics could not be considered for food contact use.

The compositional requirements outlined in the Plastics Regulation, as amended in early 2025 by Regulation (EU) 2025/351, also apply to recycled plastic FCMs. In summary, materials must be composed of substances listed in Annex I to Regulation (EU) 10/2011 and comply with the overall and specific migration limits set out in the regulation. All substances used to manufacture plastic FCMs must also exhibit a "high degree of purity," i.e., contain only a minor amount of non-intentionally added substances (NIAS).³

Typical testing procedure for FCMs containing recycled PET plastic

Due to the increased risk of breakdown product formation and contaminant presence, recycled plastic food contact materials require batch-specific testing. Extended NIAS screening is also required, as well as additional targeted analyses for hazardous compounds such as bisphenol A and primary aromatic amines (PAAs), which must be measured with detection limits lower than those achievable through NIAS testing alone.

A typical set of tests for rPET bottles contains the following analyses:

• Overall migration testing with multiple food simulants

• Sensory evaluation of odor and flavor transfer (DIN 10955)

• Extended NIAS analysis with GC/MS and LC-QTOF-MS methods

• Specific migration of elements listed in Annex II to the Plastics Regulation (EU) 10/2011

• Specific migration of ethylene glycol, diethylene glycol, acetaldehyde, terephthalic acid, and isophthalic acid

• Specific migration of primary aromatic amines

• Migration of bisphenol A

• Residual volatile organic compounds (VOCs), including benzene, styrene, limonene, and 2-methyl-1,3-dioxolane

A determination of total fluorine or total organic fluorine (TOF) and an extended targeted analysis of PFAS compounds can be added to evaluate compliance with the upcoming PFAS ban under the PPWR. The restriction will take effect in August 2026.

Requirements for recycled paper and board in food contact materials

Currently, the use of recycled paper and cardboard in food contact materials is not regulated at the EU level beyond the general safety requirements of the Framework Regulation (EC) 1935/2004. As the requirements of national legislation vary from country to country, non-binding guideline documents by the European Committee for Food Contact Materials and Articles (CD-P-MCA)⁴ or the Nordic Council of Ministers⁵ may be used to determine the appropriate safety assessment procedure. These guidelines are primarily based on Member States' national regulations and scientific opinions issued by EFSA.

According to the most recent CD-P-MCA guidance, recycled paper and board may be used in food contact applications, but their use is not recommended for certain high-risk products such as baking papers and filter papers. Where recycled fibres are used, compliance documentation should describe the recycling process in detail, including input quality, cleaning methods, and – if present – the effectiveness of a barrier layer.

Typical testing procedure for FCMs containing recycled fiber

Like recycled plastics, recycled paper and cardboard tend to contain more impurities than virgin fibers, making extended migration and/or extraction testing necessary to ensure that contaminants are not transferred to food. Typical sources of contamination include printing inks, coatings, and chemicals used during cleaning and reprocessing.

The following are some of the most commonly conducted tests when evaluating the food contact suitability of recycled paper and board:

• Sensory evaluation of odor and flavor transfer (EN 1230)

• Specific migration of mineral oil hydrocarbons (MOSH and MOAH) into Tenax

• Phthalate screening

• Total fluorine content measurement (EN 14582)

• Extended targeted PFAS analysis

• Bisphenol content determination (bisphenols A, B, F, S, and AF)

• Transfer of optical brighteners

The final selection of tests is based on a material- and application-specific risk assessment. Measurlabs provides all the required analyses to evaluate your recycled material’s suitability for food contact. Please describe the material and its intended applications (food types, short- or long-term contact, etc.) when requesting a quote. This information helps us determine the appropriate testing sequence and prepare an offer faster.