Recycled Content in Packaging: Key Considerations for Food and Cosmetics

Recyclates in packaging play an increasingly important role in the circular economy. However, especially when it comes to food and cosmetics packaging, simply using more recycled plastic is not enough. Safety, material quality, the origin of the recyclate, and legal requirements must also be taken into account.

In the Innoform web seminar “Use of Recyclates in Packaging – Requirements for Food and Cosmetics”, Dr. Christian Kirchnawy explained which requirements apply to recycled plastics and where the greatest challenges lie in using them safely.

Which Regulations Apply to Recyclates in Food Packaging?

When using recyclates in food packaging, several European regulatory frameworks interact. In particular, Regulation (EC) No 1935/2004, the GMP Regulation (EC) No 2023/2006, and the Plastics Regulation (EU) No 10/2011 were highlighted during the web seminar.

For recycled plastics in food contact, Regulation (EU) 2022/1616 is also of central importance. In this context, the Recycling Regulation can also be relevant even if the recyclate content is not directly on the food contact side, but lies behind a barrier layer, for example.

Regulatory consideration therefore already begins with the input material used and its origin.

Suitable Technology and Novel Technology

An important point when using recyclates in packaging is distinguishing between suitable technologies and novel technologies.

The web seminar explained the only suitable technologies listed so far in Regulation (EU) 2022/1616 – mechanical PET recycling and certain closed-loop systems. The decisive factor for a closed loop is that the packaging has not been used uncontrollably by the end consumer.

In contrast, all other recycling solutions must be submitted as a novel technology if the recyclate is to be approved in the EU for direct food contact. This involves specific requirements for safety assessment and monitoring. Both input and output of the recycling process must be evaluated, and regularly published monitoring reports also play a key role.

For packaging manufacturers and users, it is therefore not only the technical quality of a recyclate that matters. They must also know the regulatory basis under which the material is used for the intended application.

Why Does PET Have Advantages in Recycling?

From a food safety perspective, PET offers a key advantage: potential contaminants move relatively slowly through the polymer. This helps to limit migration from the material into the food.

For polyethylene (PE) and polypropylene (PP), greater challenges arise. Substances can migrate through the polymer more rapidly. At the same time, PE and PP can absorb contaminants, for instance during their use phase or during washing processes.

These material properties make the safety assessment of recycled polyolefins particularly challenging.

Polystyrene was also addressed in the web seminar. From a migration perspective, PS can exhibit interesting properties for recycling applications due to its slower diffusion rates.

Printing Inks and Adhesives Can Become a Problem

Particularly interesting for practical application are the potential effects of printing inks, pigments, and adhesives on recyclates.

Studies presented during the web seminar showed that certain printed materials may initially appear inconspicuous. However, the high temperatures involved in the recycling process can generate additional degradation products. Among other factors, specific ink components and pigments were discussed as potential influences.

This puts the quality of the recycling input firmly in focus.

Possible approaches include:

• sorting by color,
• rejecting unsuitable printed components,
• delabeling,
• deinking, and
• a targeted evaluation of the adhesives used.

For a functioning circular economy, packaging design must therefore increasingly account for the subsequent recycling stage.

Safety of Recyclates: Screening Is Not Always Enough

The analytics of recyclates is another key topic. GC-MS screenings play an important role, but they cannot capture all relevant groups of substances equally well.

In the presentation, reference was made to primary aromatic amines, for example. These can only be inadequately detected with classic GC screening. Depending on the recyclate and intended application, supplementary testing may therefore be advisable.

With novel technologies, additional issues come into play, such as potential genotoxic substances and endocrine disruptors, as well as handling unidentified substances.

Recyclates in Cosmetics Packaging

For recyclates in cosmetics packaging, the situation differs from food contact applications. A comparably detailed Europe-wide regulation for recycled plastics does not exist in this field.

As guidance, the voluntary industry guideline CosPaTox was introduced during the web seminar. It takes actual exposure into account, among other factors. For instance, a rinse-off product like shampoo is evaluated differently than a leave-on product like sun cream.

This approach enables a safety assessment that is more closely aligned with actual application.

At the same time, batch-to-batch evaluations can entail significant testing efforts.

What Role Does Chemical Recycling Play?

Chemical recycling of plastics was also discussed in the web seminar.

If polymers are broken down into monomers and these monomers are listed in Regulation (EU) No 10/2011, regulatory assessment can take place via the Plastics Regulation. If, on the other hand, the resulting substances are not listed accordingly, a chemical recycling process must also be submitted as a novel technology under Recycling Regulation (EU) 2022/1616.

This makes it clear: chemical recycling is not automatically tied to a single regulatory pathway.

PPWR: Are the Recyclate Targets Achievable by 2030?

The PPWR and future recyclate targets were also a topic of the web seminar.

Christian Kirchnawy expressed doubt that the requirements targeted for 2030 can be achieved comprehensively. Among the challenges, he cited the duration of procedures surrounding novel technologies. At the same time, he noted that companies are already working intensively to meet the requirements.

Thus, a crucial challenge remains: How can higher recyclate contents be combined with strict product safety requirements?

Conclusion: Safe Recyclates Start with the Input

The use of recyclates in packaging is far more than a question of percentage recycled content. The key lies in evaluating the entire process chain: from the raw input material through sorting, cleaning, and recycling to analytics and the eventual application of the material.

One of the central key takeaways from the web seminar is therefore: The quality of the input is crucial for the quality and safety of the recyclate.

Packaging manufacturers, recyclers, and users should therefore ask more specifically:

• Where does the recycled material originate from?
• Which raw materials were used?
• How are printed materials handled?
• What role do printing inks and adhesives play?
• How was the recyclate analyzed?
• Does the safety assessment match the actual application?

For a functioning circular economy, it is not just about how much recyclate is used. Just as important is how safely and controlled the cycle is designed.