Recycled plastic in food contact: Regulation EC 1935/2004

Published at 21 November 2025

The transition towards more sustainable production models is driving companies to review their materials, processes and packaging design. In the food sector, one of the key points is ensuring that the materials used, including recycled plastics, comply with the safety requirements established by European regulations.

In this context, the use of recycled plastic in food contact takes on special relevance. Technological progress, together with the update of the regulations, determines how recycled materials must be managed and what guarantees they must offer manufacturers, consumers and control authorities.

In this article, we analyse in detail the new requirements, how recycling technologies work and the practical implications for the industry.

Importance of plastic packaging in food contact

Plastic packaging plays an important role in the protection and preservation of food. Before delving into the technologies and recent regulatory changes, it is important to understand why this type of packaging continues to be essential and which factors determine its suitability for use in food contact.

Main functions of plastic packaging

Plastic remains one of the most widely used materials in the food sector due to key characteristics such as lightness, versatility and preservation capacity. Among its most important functions are:

Protecting the food from external agents such as moisture, light or oxygen.
Maintaining product quality and safety throughout its shelf life.
Facilitating transport and storage thanks to its resistance and low weight.
Reducing food waste due to its ability to extend preservation.

Challenges associated with the use of recycled plastic

The use of recycled materials in contact with food poses a series of challenges that must be properly managed. These include:

The possible presence of unwanted substances from previous uses of the material.
The need to apply advanced cleaning and treatment processes to guarantee the purity of the recycled material.
The control of migration of components into the food, a strictly regulated aspect under European legislation.
The traceability of the material used, essential for assessing its conformity.

These challenges have driven both the development of new recycling technologies and the update of regulations to ensure that recycled materials are safe and reliable.

European regulatory framework on recycled plastic materials

The European regulatory framework has evolved significantly in recent years to ensure that plastic materials intended for food contact, including recycled ones, meet strict safety criteria. This evolution responds to the need to strengthen the circular economy without compromising consumer health.

Below, we analyse the most relevant regulations and the changes introduced recently.

Current regulations and basic principles

Three regulatory pillars make up the current framework:

Regulation (EC) 1935/2004. Establishes that any material in contact with food must be safe, not transfer substances in harmful quantities and not alter the organoleptic characteristics of the food.
Regulation (EU) 10/2011. Specifically regulates plastic materials and articles. It includes positive lists, specific migration limits and technical criteria for manufacturing.
Regulation (EU) 2022/1616. Introduces requirements for recycling processes and for recycled plastic materials intended for food contact. It strengthens traceability and control systems.

Regulatory update: Regulation (EU) 2025/351

Regulation (EU) 2025/351 introduces important changes to the two previous regulations to improve clarity and ensure more exhaustive control over recycled plastic. Among the most relevant new features are:

A clarification of the scope, specifying that composition requirements apply to complete plastic materials and articles, not only to their layers.
New definitions of “recycled plastic” and “reprocessed”, facilitating correct classification.
Stricter requirements on purity, migration and analytical control of the recycled material.
Reinforcement of traceability, documentation and continuity obligations throughout the manufacturing process.
Clear criteria for multilayer packaging where not all layers are plastic.

These changes improve the safety of using recycled plastic and make regulatory compliance easier for companies.

Impact on the food and packaging industry

With the entry into force of Regulation (EU) 2025/351, manufacturers will need to review their internal control systems, update technical documentation and ensure that recycled material suppliers provide verifiable evidence of conformity.

Key points to consider include:

Evaluation of each batch of recycled material through migration and purity tests.
Complete documentation of material traceability.
Updated Declarations of Conformity in accordance with the new regulation.
Reinforced internal control for reusable or multilayer packaging.

This regulatory framework establishes a common and harmonised basis for all operators, improving consumer safety and the functioning of the European market.

Recycling technologies applied to food contact

The industry has developed various technologies to produce recycled plastic suitable for food contact. These technologies seek to ensure that materials meet the required quality standards and that their performance is equivalent to that of virgin material.

Below, we explain the main processes and their relevance:

Mechanical recycling: One of the most widespread processes and is based on the recovery, shredding, washing and extrusion of plastic. For food-contact applications, this method is complemented by advanced systems that include:

Intensive cleaning to remove ink residues, adhesives or contaminants.
Melt filtration to eliminate unwanted particles.
Deodorisation to reduce volatile compounds.

Chemical recycling: Transforms the polymer into its original monomer components through processes such as depolymerisation or solvolysis. This method allows obtaining material with characteristics very similar to virgin plastic. It is especially useful for plastics that present difficulties for mechanical recycling.

Functional barriers and multilayer structures: Multilayer packaging combines different materials to improve performance, which may include layers of recycled plastic. The challenge is ensuring that there is no migration from internal layers into the food. Regulations allow the use of functional barriers as long as it is demonstrated that the material meets established migration limits.

Traceability and analytical control

Regardless of the recycling method, global and specific migration tests are essential. In addition, material traceability must be documented at every stage of the process, ensuring that the origin, treatment and destination of the recycled material are verifiable.

Good practices for ensuring compliance

To comply with European regulations and ensure consumer safety, companies must implement appropriate control and verification procedures. Some recommended good practices include:

Supplier auditing: It is essential to work with recycled material suppliers who can provide documentary evidence of the recycling process, analytical tests and certifications proving traceability.
Internal quality control: Manufacturers must carry out periodic migration tests, evaluate incoming batches and verify that the materials meet regulatory criteria.
Complete documentation: The Declaration of Conformity must always be up to date and include detailed information on the composition, intended use and conditions of employment of the material.
Packaging design oriented towards recyclability: Whenever possible, it is recommended to prioritise monomaterials or simplified structures that facilitate future recycling of the packaging.

Conclusion

The use of recycled plastic in food contact is advancing decisively thanks to the momentum of mechanical recycling, a reliable technology that makes it possible to obtain safe materials compliant with European regulations. At ___, we specialise in this process and work under the most demanding standards to guarantee traceability and quality.

Frequently Asked Questions

Is it safe to use recycled plastic in contact with food?
Yes, as long as it meets the requirements established in European regulations and the recycling process guarantees the purity of the material.
What changes with Regulation (EU) 2025/351?
This regulation clarifies the scope of 10/2011, strengthens purity and migration controls and updates requirements for recycling processes and multilayer materials.
Which technologies make it possible to obtain recycled material suitable for food contact?
The main technologies are advanced mechanical recycling and chemical recycling, both designed to ensure material safety and traceability.
What obligations does a manufacturer using recycled plastic have?
They must ensure complete traceability, carry out migration tests, keep the Declaration of Conformity up to date and work with certified suppliers.
What benefits does the use of recycled material offer in food packaging?
It supports the circular economy, reduces the use of virgin resources and helps companies meet environmental objectives established in European regulations.