The use of recycled plastics in food contact applications is increasing rapidly, driven by sustainability targets and evolving European regulations. At the same time, companies across the plastics value chain are facing growing pressure to demonstrate compliance with complex and interconnected regulatory requirements:
- The Recycled Plastic Materials and Articles Intended to Come into Contact with Food, Regulation (EU) 2022/1616 introduces process control covering waste collection, recycling and the production of the final article, through a Quality Assurance System certified by an independent third-party certification body.
- The Packaging and Packaging Waste Regulation (EU) 2025/40 (PPWR) strengthens sustainability and traceability obligations across the packaging value chain.
- The Single Use Plastics Directive (EU) 2019/904 (SUPD) further impacts materials, production processes and market access.

Why existing certification routes are not enough
Industry capacity is currently constrained by the limited availability of audit protocols. As a result, companies face growing exposure to regulatory non-compliance, delays in market approval or validation, and the risk of product withdrawals or recalls.
Developed in collaboration with industry stakeholders,the RINA Food Contact Recycled Plastics Audit Protocol has been designed to address these challenges.
The protocol:
- incorporates, as best practice, the recent EU Commission guidance on the PPWR and proposed amendments to Regulation (EU) 2022/1616, as well as the SUPD implementing decision (included in the “Winter Package”), which introduce additional requirements and mandatory standards.
- is built upon a chain of custody approach, ensuring traceability of recycled plastic raw material batches throughout the recycling process.
- offers an EU audit protocol to support audits of recycling facilities both within and outside the EU (third countries) supplying materials to food contact packaging producers placing products on the EU market.