EU Regulation 2022/1616 - What You Need to Know

EU Regulation 2022/1616 represents a significant regulatory shift in how recycled plastic materials are authorized for use in food contact applications. For Recyclers, Converters, Packaging Manufacturers,  Industry Associations and Brand owners, the regulation creates both responsibility and opportunity — particularly in guiding through complex testing, documentation, and authorization pathways. 

This post outlines what the regulation means for your organization.

What Is EU 2022/1616? 

The regulation replaces EC 282/2008 and introduces tighter controls over recycled plastics used in food packaging. Its aim is to ensure recycled materials meet the same health and safety standards as virgin plastics. 

Key shifts include: 

• A technology-specific approval model for recycling processes 
• Clear procedures for individual recyclers and converters 
• Obligations for testing, verification, and documentation for multilayer systems and functional barriers 
• Greater scrutiny of NIAS (non-intentionally added substances) 
• Major Articles of Interest for Associations 
• Article 32 – Functional Barrier Validation 
• Requires migration testing into food simulants 
• Must include worst-case scenarios and surrogate contaminant testing 
• NIAS Screening, Overall and specific migration, targeted substances
• The regulation demands a comprehensive risk assessment of NIAS, including: 
• Substance identification 
• Quantification 
• Toxicological evaluation (where needed) 

Dossier & Documentation Requirements 

• Each compliant process must be documented in a technical dossier, covering: 
• Recycling steps 
• Quality control measures 
• Analytical testing 
• Safety justifications 
• Communication with downstream actors (e.g. Certificate of Compliance) 
• Associations can provide templates, review procedures, and technical assistance. 

The Possible Roles of Associations  

Your members — recyclers, packaging suppliers, converters — are now subject to new testing burdens, unfamiliar workflows, and stricter documentation audits. 

You are uniquely positioned to: 

• Coordinate group testing (e.g. NIAS, migration, barrier studies) 
• Centralize regulatory interpretation and risk communication 
• Provide validated protocols and model documentation 
• Reduce duplication of effort and cost across the sector 
• Associations are now compliance enablers, not just information hubs. 

How Does KÖR Support? 

At KÖR, we: Provide standardized testing via certified  proven laboratories 

• Support Article 32 validation with scalable protocols 
• Deliver NIAS screening and evaluation 
• Power testing and data through Labs, our digital testing platform 

Whether you are a Recycler, Converters, Packaging Manufacturer, Brand Owner, or  Industry Association we help you fast, transparently, and affordably. 

Ready to Strengthen Your Testing Needs to meet Compliance? 

Explore possible partnership tailored to your needs!