Key data
| Regulation | Regulation (EU) 2026/2376 of the Commission, of 28 October 2026 |
|---|---|
| Amends | Regulation (EU) 2022/1616 on recycled plastic materials and articles in food contact |
| Publication | 29 October 2026 |
| Entry into force | Not specified in the published regulation |
| Affected parties | Manufacturers, importers and users of recycled plastics in food packaging |
| Category | European Regulation |
| Scope | European Union |
If your company manufactures recycled plastic packaging, imports it or uses it to package food, this regulation requires you to review your internal procedures before it enters into force. The Regulation (EU) 2026/2376, published on 29 October 2026, amends Regulation (EU) 2022/1616 in four specific areas that directly affect daily operations and customs procedures.
This is not a minor revision: the changes affect the documentation you must issue, the tests you must perform and the papers you must submit when material crosses an EU border. Ignoring it can paralyze an import or generate a penalty.
What does this regulation establish?
Regulation (EU) 2026/2376 introduces amendments in four blocks of the current regulatory framework for recycled plastics in food contact:
| Modified block | What changes | Operational impact |
|---|---|---|
| Union Register | The management rules of the register where authorized recycling technologies are registered are updated | Companies must verify that their technology remains registered and meets the new register management criteria |
| Conformity documentation | The requirements for documents that operators must issue to certify material conformity are modified | Review and update of templates, declarations and internal conformity records |
| Test methods | The applicable methods to verify the safety of recycled plastics are updated | Possible need to repeat or update tests already performed under previous methods |
| Release for free circulation | The documents required at customs at the time of clearance are modified | Update the documentation accompanying each import to avoid delays or denials |
The reference framework remains Regulation (EU) 2022/1616, which specifically regulates recycled plastic materials and articles intended to come into contact with food. The new regulation does not repeal it: it amends it in these four specific points.
Economic and operational impact
The changes do not involve new fees or published amounts, but they do generate real operational costs for affected companies:
- Documentation adaptation costs: Reviewing and updating conformity declarations, internal records and customs clearance documents requires time from technical and legal staff.
- Test costs: If the updated test methods differ from those previously applied, it may be necessary to repeat tests in an accredited laboratory, with the associated cost.
- Risk of customs paralysis: Denial of release for free circulation due to incorrect documentation can result in goods being held, storage costs and supply chain delays.
- Risk of penalty: Food control authorities may impose penalties on operators who do not comply with the new conformity requirements.
The cost of not acting—delays, penalties, loss of goods—far exceeds the cost of a preventive review of procedures.
Who does it affect?
- Manufacturers of recycled plastic materials and articles intended to come into contact with food (packaging, trays, bottles, caps, films, etc.).
- Importers who introduce recycled plastics or products manufactured with them into the EU for food use.
- Industrial users who use recycled plastics in their food packaging or processing lines.
- Operators of recycling technologies registered or wishing to register in the Union Register.
- Quality, compliance and supply chain managers in food, beverage and packaging companies.
Practical example
A Spanish company that imports recycled PET bottles from a non-EU supplier to package mineral water must, at the time of release for free circulation at customs, present the documentation required by Regulation (EU) 2022/1616 as amended by Regulation (EU) 2026/2376.
If that company continues to present documents in the previous format—the one in force before the new regulation enters into force—customs may deny clearance. This means goods held, storage costs in the customs zone and possible return to origin if not corrected within the deadline. Additionally, if food control authorities detect that the material has not been verified using the updated test methods, they may initiate a penalty proceeding.
The solution is to anticipate: review with the supplier that their recycling technology remains registered in the Union Register under the new criteria, update the conformity declaration to the new format and confirm that tests have been performed using the current methods.
What should companies do now?
- Identify if you use recycled plastics in food contact: Review your supply chain and confirm if any material or packaging in your operation falls within the scope of Regulation (EU) 2022/1616.
- Verify the status of the Union Register: Check that your supplier's recycling technology remains registered and meets the new register management criteria.
- Update conformity documentation: Review conformity declarations and internal records to adapt them to the new documentary requirements of the amended regulation.
- Review the test methods applied: Confirm with your laboratory or supplier that material safety tests have been performed—or can be repeated—using the updated test methods.
- Update customs documentation: If you import recycled plastics or products manufactured with them, update the documents you present at release for free circulation to avoid delays.
- Train your quality and logistics team: Ensure that quality, compliance and customs operations managers are aware of the new requirements before entry into force.
Frequently asked questions
What is the Union Register of recycling technologies and how does it affect me?
It is the official register where authorized recycling technologies for producing plastics in food contact in the EU are registered. Regulation (EU) 2026/2376 modifies the management rules of that register. If your supplier uses a registered technology, you must verify that it continues to meet the new criteria; if it is not registered, the material cannot legally be used in food contact in the EU.
What conformity documentation should I update as a manufacturer or importer?
The regulation modifies the requirements for documents that operators must issue to certify the conformity of recycled plastic. Although the full text of the new formats is in the regulation published on 29 October 2026, you must review your current conformity declarations and adapt them to the new requirements before entry into force. Consult the official regulation for the exact details of the new format.
What happens if I submit incorrect documentation at customs?
According to Regulation (EU) 2026/2376, failure to comply with documentary requirements at the time of release for free circulation can result in denial of customs clearance. This implies goods being held, storage costs and possible returns to origin. Additionally, food control authorities may impose penalties.
When does Regulation (EU) 2026/2376 enter into force?
The exact date of entry into force is not specified in the information published on 29 October 2026. It is essential to consult the full text of the regulation in the Official Journal of the EU to know the specific date and any transitional periods.
Do I need to repeat the safety tests of my materials with the new methods?
The regulation updates the applicable test methods to verify the safety of recycled plastics. If your material tests were performed under the previous methods, you will need to assess—with your accredited laboratory—whether they are valid under the new methods or if they need to be repeated. Failing to do so may invalidate your conformity documentation.
Official source
Consult the complete regulation at official source
Disclaimer: This article is for informational purposes only and does not constitute legal advice. For specific decisions, consult a qualified professional. Source: https://eur-lex.europa.eu/./legal-content/AUTO/?uri=OJ:L_202602376
