Testing to support plastic recycling in accordance with EU requirements

The EU Packaging and Packaging Waste Regulation (PPWR) sets minimum quotas for the proportion of recycled content in plastic packaging from 2030, with stricter targets taking effect in 2040.¹ These quotas are set to significantly increase the demand for high-quality plastic recyclates, including those suitable for food-contact applications.

Producing recycled plastics that meet the applicable quality criteria requires meticulous quality assurance throughout the supply chain, from ensuring the suitability of plastic waste for recycling to evaluating the effectiveness of the decontamination process and the quality of the output plastic. Measurlabs offers the required laboratory testing to support operators at each stage of the process.

Plastic recycling technologies and their treatment under EU law

Plastic recycling combines several physical and/or chemical steps to pretreat, decontaminate, and reprocess waste into new materials and products. The three main approaches are:

• Mechanical recycling, where waste is processed through mechanical and physical processes (sorting, washing, grinding, extrusion, etc.) without making changes to its chemical structure. 

• Solvent-based recycling, where heat and solvents are used to dissolve plastic waste into a solution, from which polymers and additives can be separated without altering their chemical structure.

• Chemical recycling, where waste is broken down into its chemical constituents through a process such as pyrolysis or depolymerization, before being used to produce new polymers.

EU policy generally prefers mechanical recycling, which requires less energy than chemical recycling and therefore provides clearer environmental benefits. This preference is stated in the recitals of Implementing Decision (EU) 2026/1425 on the calculation of recycled content in plastic beverage bottles, according to which chemical recycling should not, in principle, be used when mechanical recycling can produce recyclates of comparable quality. Instead, it should be primarily reserved for more challenging waste streams.²

Chemical purity requirements for recycled plastic under EU end-of-waste criteria

Recycled plastic must meet certain quality and purity criteria to no longer be considered waste and to therefore be freely tradable on the EU market. An implementing regulation establishing harmonized, EU-wide end-of-waste criteria for plastic is currently in the draft stage.³ It sets requirements for the input waste, the recycling process, and the quality of the recyclate from mechanical and solvent-based recycling operations. From a testing perspective, the chemical purity criteria for the output plastic are particularly relevant:

• The recyclate must not be classified as hazardous under the CLP Regulation (EC) No 1272/2008, for example due to containing carcinogenic, mutagenic, or reprotoxic (CMR) substances in excess of classification thresholds.⁴

• It must comply with dangerous substance restrictions outlined in Annex XVII to the REACH Regulation (EC) No 1907/2006. Examples of restricted substances that may be present in recycled plastic include phthalates, lead, cadmium, and polyaromatic hydrocarbons (PAHs).

• It must comply with authorization provisions outlined in Article 56 of the REACH Regulation. Compliance can be demonstrated by showing that the recyclate does not contain substances on the Annex XIV authorization list in excess of the applicable concentration limits.⁵ As all Annex XIV substances are also on the candidate list of substances of very high concern (SVHCs), a full SVHC screening can also be performed.

• It must not contain persistent organic pollutants (POPs) in excess of the unintentional trace contaminant limits specified in Regulation (EU) 2019/1021.⁶ Examples include brominated flame retardants (PBDEs, HBCDD), PFAS compounds (PFOS, PFOA, PFHxS) and short-chain chlorinated paraffins (SCCPs).

The input plastic may contain restricted substances, but the recycling process must remove them effectively enough for the output to meet the criteria. Measurlabs offers extensive screening for contaminants restricted under the REACH, CLP, and POPs Regulations in both the input and output plastic, allowing recyclers to verify that sufficient decontamination efficiency is achieved.

Standard methods for the characterization of plastic recyclates

In addition to not containing excessive concentrations of hazardous substances, recycled plastic must have appropriate physicochemical and mechanical properties to effectively substitute virgin plastic in the intended application. Several EN standards outlining the key characteristics of different recycled polymers, along with associated test methods, were published or updated between 2024 and 2026. These are listed in Table 1.

Properties covered under the characterization standards include the following:

• Color and form by visual inspection

• Melt flow index (MFI)/melt mass flow rate (MFR) (ISO 1133)

• Viscosity by capillary viscometer (ISO 1628)

• Density (ISO 1183) and bulk density (ISO 60, ASTM D1895)

• Particle size distribution by sieve analysis (ASTM D1921)

• Melting and crystallization points by differential scanning calorimetry (ISO 11357)

• Ash content (ISO 3451)

• Residual moisture content (ISO 15512, ASTM D6980, EN 12099)

• Residual contaminants (annexes to the respective characterization standard)

• Volatile organic content/emissions (EN 16516)

• Vicat softening point (ISO 306)

• Tensile stress and strain, Young’s modulus (ISO 527 series)

• Impact strength by Charpy (ISO 179) or Izod (ISO 180) method

• Shore hardness (ISO 868)

• Flexural modulus (ISO 178)

Only a subset of these tests is mandatory under each characterization standard. For example, the mandatory assessments for general purpose polystyrene (GPPS) recyclates under EN 15342 are color, form, melt mass flow rate, and impact strength.

Further tests are selected based on polymer grade, intended use, and customer specifications. As a general rule, more extensive characterization is required when the recyclate is used to manufacture products that must withstand sustained mechanical stresses or high or low temperatures, for example in the automotive or construction industries.

Additional requirements for food-grade recycled plastic

Recycled plastic intended for food-contact applications must comply with the same general quality requirements and compositional criteria as virgin food-grade plastics, as specified in the Framework Regulation (EC) No 1935/2004 and Regulation (EU) No 10/2011 on plastic food contact materials. In addition, it must be produced using either a suitable recycling technology listed in Annex I to Regulation (EU) 2022/1616, or a novel technology being developed in accordance with Articles 10 to 13 of the same regulation.⁷

The list of suitable recycling technologies currently includes mechanical recycling of post-consumer PET and recycling of food-grade plastic within a closed product loop. Each PET recycling process must be authorized separately, and the operator must provide a comprehensive set of data on the decontamination efficiency of the process and quality of the output plastic to substantiate the application for authorization.

Even more information on the recycling process and its efficiency is required for the novel technology route, demonstrating that the input plastic is consistently decontaminated to such an extent that the output plastic does not release unsafe amounts of chemicals into food. Reports detailing the decontamination efficiency must be published every six months, and after four consecutive reports have been published, the developer can request an evaluation of the technology for the purpose of including it on the list of suitable recycling technologies.⁸

On a practical level, decontamination efficiency is usually demonstrated with a challenge test, in which surrogate contaminants are deliberately added to the input plastic, and their residual levels are measured in the recyclate after processing.⁹ To demonstrate that the output plastic is food grade, overall migration and specific migration tests are also required, along with extensive screening and risk assessment of non-intentionally added substances (NIAS). NIAS testing in particular typically needs to be considerably more extensive than for virgin plastic, as the risk of contamination and formation of degradation products is significantly higher.

Laboratory testing for recycled plastics

Measurlabs offers the laboratory tests required at each stage of plastic recycling, from screening incoming waste for restricted substances to demonstrating that the final recyclate is safe for food contact. Popular services include:

• POP testing of plastic waste and recyclates, covering substances often found in recovered plastic

• Screening of substances restricted under the REACH and CLP Regulations, including phthalates, heavy metals, PAHs, PFAS, and CMR impurities

• SVHC screening covering the full list of compounds on the candidate list

• Custom characterization packages to determine recyclate properties in accordance with EN standards

• Overall and specific migration tests for recycled food contact materials

• Extensive NIAS screening with GC-MS and LC-QTOF-MS, including risk assessment based on EFSA’s Threshold of Toxicological Concern (TTC) approach

Our experts can help formulate a testing plan that suits your material and matches any specific requirements regarding detection limits and other practical details. Use the form below to tell us about your testing needs, and we will get back to you within one business day.