OpenLobby.EU
Explore

Amendment of Regulation (EU) No 282/2008 on the recycling of plastic materials to be used as food contact materials

Food safety

All food contact materials must be safe. Operators must exclude the potential presence of toxic contaminants. Regulation (EU) No 282/2008 thereto foresees individual authorisations for plastic recycling processes. In anticipation, this amendment sets out transitional provisions, provisions for the appropriate evaluation of non-PET materials, and clear obligations for operators and competent authorities. It also clarifies chemical recycling, closed-loop recycling and functional barriers.

Links

Public consultation

ID: 12013

Lobbying Activity

46 responses

Chemical Industry Seeks Flexibility in Recycled Plastics Rules

European Chemical Industry Council, 17 Jan 2022

The industry wants regulators to focus on overall decontamination capability rather than strict requirements for each process step. They seek looser rules for novel technologies and third-party assessment for imports instead of local authority validation.
This would reduce compliance burdens and enable faster market access for chemical recycling processes.
Consumer safety advocates lose stricter safeguards against contaminants in recycled food packaging.

Consultation response

FoodDrinkEurope, 18 Jan 2022

FoodDrinkEurope welcomes the progress made on this long-awaited text and hopes it will accelerate the long due authorization of recycling processes that have been positively evaluated by EFSA. This revision should foster innovation and ensure that the right infrastructure and technologies are in…

Consultation response

Plastics Europe, 17 Jan 2022

Plastics Europe and its member companies - who produce over 90% of all polymers across Europe – welcome the initiative of the European Commission to revise the EU rules on recycled plastic intended to come in contact with food and are pleased to have the opportunity to provide feedback. We, as…

Consultation response

Zero Waste Europe, 18 Jan 2022

We thank the Commission for the opportunity to provide comments on this draft Regulation. Most plastic food contact materials (FCMs) on the market today (with or without recycled content) can contain several known hazardous chemicals which are authorized by the EU, as well as many chemicals that…

Consultation response

Veolia Environnement, 18 Jan 2022

Draft Regulation on recycled plastic materials and articles intended to come into contact with foods VEOLIA welcomes the revision of Regulation 282/2008. VEOLIA supports the general idea behind the revision of Regulation 282/2008, i.e. the importance of producing recycled plastics for food…

Consultation response

The European Organisation for Packaging and the Environment, 18 Jan 2022

To protect the product, guaranteeing safety and hygiene for consumers, is a key functionality of packaging and the first priority for the food and drink packaging supply chain. It is also what drives the search of the most sustainable packaging solutions, including for the further uptake of…

Consultation response

Schwarz Corporate Affairs International GmbH, 18 Jan 2022

Die Schwarz Gruppe ist ein international führendes Handelsunternehmen. Sie setzt sich aus den beiden Handelssparten Lidl und Kaufland, der Schwarz Produktion und der Umweltsparte PreZero zusammen. Die Schwarz Produktion zählt zu den führenden Getränkeherstellern und Recyclern von…

Consultation response

European Recycling Industries' Confederation, 18 Jan 2022

EuRIC welcomes the draft regulation on recycled plastic materials and articles intended to come into contact with foods, repealing Regulation (EC) No 282/2008. These updated rules can serve as a means to increase plastics recycling capacity across Europe, fostering its competitiveness through the…

Consultation response

Plastics Recyclers Europe, 14 Jan 2022

We welcome the new Regulation’s scope extension to cover a broad range of recycled plastics and the structural changes that lead to a well-defined approval path for novel recycling processes. The fast-track authorisation process for the suitable technology represents a significant improvement,…

Consultation response

PepsiCo, 18 Jan 2022

PepsiCo welcomes the opportunity to provide feedback on the draft Regulation for Recycled Plastic Materials and Articles intended to come into contact with foods. Food contact plastics have an essential role on delivering the European Union vision for a circular economy. It is essential as…

Consultation response

Union of European Beverages Association, 17 Jan 2022

UNESDA Soft Drinks Europe welcomes the opportunity to provide comments on the draft regulation on recycled plastics for food contact. We support the overall objective of this draft regulation in enabling growth of recycling capacities within the EU by establishing an efficient authorization…

Consultation response

FEAD, 18 Jan 2022

FEAD, the European Waste Management Association, representing the private waste and resource management industry across Europe, welcomes the draft regulation in its intention to promote the development of new recycling technologies and to harmonise the scope and controls on all stages of plastic…

Consultation response

Flexible Packaging Europe, 18 Jan 2022

Flexible Packaging Europe welcomes the opportunity to provide feedback on this important piece of legislation. We are supportive of the overall direction of the draft, but highlight several shortcomings which may inhibit the take up of recyclates in flexible packaging. Article 2, paragraph 3,…

Consultation response

International Chemical Secretariat, 18 Jan 2022

Background In line with the chemical strategy for sustainability, the EU has committed to reduce the presence of hazardous chemicals in FCMs. The draft regulation seems to set this priority aside and instead only focusing on increasing the use of recycled material which is to the aims set by the…

Consultation response

The Food and Beverage Carton Alliance, 18 Jan 2022

Thank you for the opportunity of submitting comments on the draft Regulation. Please find our views attached in the document below.

Consultation response

The European Consumer Voice in Standardisation, 18 Jan 2022

ANEC has long expressed concern on the problems that may occur when using recycled materials without adequate control of the virgin materials. While we still wait for a comprehensive revision of the EU legislative framework on Food Contact Materials to improve chemical safety for consumers and the…

Consultation response

European Plastics Converters Association, 18 Jan 2022

PET Sheet Europe represents its members who are among the European PET Sheet converters. PET Sheet Europe is a sub-sector group of European Plastic Converters Association (EuPC) We welcome the European Commission’s plan to update food-contact plastic regulations and are grateful for the…

Consultation response

Natural Mineral Waters Europe aisbl, 18 Jan 2022

Natural Mineral Waters Europe (NMWE) supports the objective of the Commission's draft Regulation on recycled plastic materials intended to come into contact with foods and welcomes the opportunity to provide comments. Our contribution can be found attached.

Consultation response

BDE Bundesverband der Deutschen Entsorgungs-, Wasser- und Kreislaufwirtschaft e. V., 18 Jan 2022

Please see the attached file.

Consultation response

PETCORE EUROPE, 17 Jan 2022

PETCORE-Europe (PETCORE), is a leading Association representing the voice of the PET industry. Our association/member’s objective is to ensure the sustainable growth of PET as a packaging material of choice, increasing PET collection and recycling. We strongly welcome and support the European…

Consultation response

European Bioplastics, 17 Jan 2022

European Bioplastics believes that the draft Regulation favours current technologies, which are already developed at scale, as opposed to innovative new products and materials. In addition, the current requirements and definitions are adapted to accommodate mechanical rather than chemical…

Consultation response

Hospodářská komora České republiky, 10 Jan 2022

There is a question whether it is truly necessary to issue both Declarations of Compliance for recycled plastic materials and articles intended to come into contact with food according to this new Regulation (Annex III) and as well as the Regulation (EU) No 10/2011 (Annex IV)?

Consultation response

Federazione Italiana dell'Industria Alimentare, 18 Jan 2022

As Federalimentare, Italian Food and Drink Industry Federation, we share and support the position and the comments finalized by FoodDrinkEuope (see attached file: FoodDrinkEurope feedback to consultation on recycled plastics 17gen2022 final)

Consultation response

Braskem Netherlands, 18 Jan 2022

Braskem Netherlands B.V., in line with the UN's sustainable development goals, has made commitments to people and our planet. We have structured our macro objectives in 7 different dimensions: Health and Safety, Economic and Financial Results, Elimination of Plastic Waste, Combating Climate Change,…

Consultation response

TotalEnergies Corbion B.V., 17 Jan 2022

TotalEnergies Corbion launched the world’s first commercially available chemically recycled bioplastics product. Our recycled PLA grades boast the same properties, characteristics and regulatory approvals as virgin PLA, but are partially made from post-industrial and post-consumer PLA waste.…

Consultation response

Extended Producer Responsibility Alliance, 18 Jan 2022

The Extended Producer Responsibility Alliance (EXPRA) welcomes the revision of Regulation 282/2008 which should result in the necessary certainty for the recycled plastic supply chain and users of recycled plastics in food contact applications. This supply chain includes EPR schemes who play a…

Consultation response

Fédération Nationale des Activités de Dépollution et de l'Environnement, 18 Jan 2022

Please find FNADE's feedback attached.

Consultation response

SAFE, 17 Jan 2022

SAFE’s feedbacks on European Commission’s draft act on Food safety – recycled plastic in food packaging (updated rules) About Safe Food Advocacy Europe – SAFE SAFE – Safe Food Advocacy Europe was created with the aim of ensuring that consumer’s health and concerns remain at the core of the EU’s…

Consultation response

TOMRA Systems ASA, 18 Jan 2022

TOMRA is the leading technology provider for collection and sorting solutions enabling the circular economy. We strongly support the efforts undertaken by the European Commission to review Regulation 282/2008 and the novel approach to food contact recycled plastics that allows for innovations to…

Consultation response

ALPLA Werke Alwin Lehner GmbH Co KG, 18 Jan 2022

ALPLA is a worldwide active (178 plants in 45 countries) leading company in plastic packaging design and production, we are also recyclers with nine mechanical recycling plants operating worldwide. First of all, we support the position papers by IK, PRE, EuPC and PCEP. Further, we have specific…

Consultation response

LanzaTech EU B.V, 18 Jan 2022

LanzaTech welcomes the European Commission's plan to update food-contact plastic regulations to enable safe use of recycled plastic in support of the circular economy. We note that complete chemical depolymerization processes providing monomers, for example as done by thermal or thermocatalytic…

Consultation response

Polyolefin Circular Economy Platform, 18 Jan 2022

The Polyolefin Circular Economy Platform (PCEP) welcomes the European Commission’s future proof approach to food contact recycled plastics that allows for innovation in recycling technologies. As we noted in previous consultations there is an urgent need to update Regulation 282/2008 to enable the…

Consultation response

CITEO, 14 Jan 2022

The European Commission has just launched a public consultation, opened until the 18th of January 2021, on recycled plastic materials and articles intended to come into contact with foods, and repealing Regulation n°282/2008. This initiative aims to ensure recycled plastic materials used with food…

Consultation response

IFP Energies nouvelles, 17 Jan 2022

IFP Energies nouvelles has analyzed the recast of Commission regulation (EC) No 282/2008 on recycled plastic materials and articles intended to come into contact with foods (consultation document), and would like to bring forward its concern about BHET classification. Our comprehension of the…

Consultation response

PET EUROPE - Producers' Association aisbl, 18 Jan 2022

Please find attached supplementary feedback from CPME

Consultation response

Food Packaging Forum Foundation, 18 Jan 2022

The Food Packaging Forum (FPF) is a charitable, science-based organization at the science-policy interface. FPF is dedicated to raising awareness for hazardous chemicals in all types of food contact materials and articles (FCMs and FCAs). Our work enables science-based decision making in the…

Consultation response

Styrenics Circular Solutions, 17 Jan 2022

SCS, the value chain initiative to realise the circular economy for polystyrene (PS), welcomes the opportunity to comment on the draft regulation repealing Reg. 282/2008. We share the circular economy objectives expressed in recital 1, while the safety of all our processes and materials and the…

Consultation response

Pyrowave, 18 Jan 2022

Pyrowave is a pioneer in the electrification of chemical processes based on low-carbon footprint microwaves. Pyrowave has been a leader in the plastics circular economy and chemical recycling for the last decade. Its unique, patented technology regenerates post-consumer and post-industrial plastics…

Consultation response

Felelős Élelmiszergyártók Szövetsége, 18 Jan 2022

The Federation of Hungarian Food Industries welcome the European Commission's efforts to create a regulation that encourages and promotes the use of those recycled plastics and plastics containing recycled plastics that come into contact with food (FCM) with precise, forward-looking standards. We…

Consultation response

Gustaaf Bos Consulting, 18 Jan 2022

In order to avoid confusion with ordinary recycled plastics and artisles made of them, I suggest the following change of definitions - "Recycled food contact plastic" or "recycled FC plastic" = Intermediate material from decontamination - "Recycled plastic food contact materials and articles" or…

Consultation response

Chemical Recycling Europe, 18 Jan 2022

Chemical Recycling Europe represents its members involved with chemical recycling technologies and the European chemical recycling industry. We welcome the European Commission’s plan to update food-contact plastic regulations to account for innovative technologies and the opportunity to provide…

Consultation response

Normpack, 17 Jan 2022

The Business group Normpack (normpack.se) thank you for the opportunity to give feedback on the proposal on new EU legislation covering recycled plastics for food contact. We support the draft for a new regulation as it states that: • the ambiguity in today’s situation is resolved • there are…

Consultation response

ELIPSO, 17 Jan 2022

Elipso, an association representing plastic packaging manufacturers engaged in circular transformation, welcomes the launch of the revision work working towards better harmonisation between the different EU Member States. This regulation is a necessary common ground for all stakeholders. Plastic…

Consultation response

APK AG, 17 Jan 2022

APK AG welcomes the initiative of the European Commission to define a framework and conditions for the use of plastic recyclates in food contact materials. As the current revision still contains some challenges to innovation, we would like to contribute the following points from the perspective of…

Consultation response

IK Industrievereinigung Kunststoffverpackungen e.V., 13 Jan 2022

We, the German Plastic Packaging Association (IK), comment on the Commission's draft in abbreviated form as follows. Attached is our regular statement. 1. Impact assessment for proposal is necessary We call on the Commission to analyse, in particular, the impact of the new rules on the…

Consultation response

Associação Portuguesa para a Defesa do Consumidor, 10 Jan 2022

Os materiais e objetos destinados a entrar em contacto (MCA) com os géneros alimentícios protegem os alimentos, mas podem também ter um impacto negativo na qualidade e segurança dos alimentos ao longo da cadeia alimentar. Sabe-se, por exemplo, que alguns químicos presentes nos materiais em contacto…