Good Manufacturing Practice (GMP) for Recycled Plastic in Food Contact Materials

20 Mar 2026

Recycled plastics in food contact materials (FCMs) are at the centre of the sustainability and regulatory landscape. As demand for circular packaging solutions continues to grow, the European Commission is strengthening the regulatory framework to ensure that recycled plastics entering the food chain are safe, traceable, and of high quality.

Good Manufacturing Practice (GMP) plays a central role in this effort by ensuring that FCMs are consistently produced and controlled in accordance with applicable regulatory requirements. However, the use of recycled plastics presents specific challenges, including potentially unknown source materials, contamination risks, and variable input quality. Robust GMP systems are therefore essential to manage the safety and quality of these materials.

In practice, GMP systems support the control of chemical, physical, and microbiological contamination. They also improve traceability across complex supply chains and form the foundation of regulatory compliance for recycled plastic suitable for food contact.

This article discusses the current GMP requirements applicable to recycled plastic FCMs, and outlines what business operators need to know to stay compliant.

Regulatory Framework Overview

The European Union (EU) regulatory scheme for recycled plastic FCMs has evolved significantly in recent years, most recently with the adoption of Regulation (EU) 2025/351. Together, several interlinked legislative instruments establish the requirements applicable to recycled plastic.

Key EU legislation governing recycled plastic FCMs includes:

• Framework Regulation (EC) 1935/2004
• Sets out the general safety and compliance requirements applicable to all FCMs.
• GMP Regulation (EC) 2023/2006
• Establishes GMP requirements applicable to all FCMs (excluding starting substances).
• Amended by Regulation (EU) 2025/351 to strengthen quality control measures and expand GMP obligations for recycled plastics.
• Regulation (EU) 2022/1616
• Provides a harmonised legal framework for the production and use of recycled plastic intended for food contact, repealing Regulation (EC) 282/2008.
• Sets out requirements for acceptable recycling technologies, recycler obligations, process authorisation, and quality assurance systems to ensure chemical and microbiological safety of recycled plastics.
• Amended by Regulation (EU) 2025/351 to clarify how the migration testing and high purity requirements of Regulation (EU) 10/2011 apply under Regulation (EU) 2022/1616.

Below, we break down the key GMP-related requirements across these regulatory instruments and highlight what they mean in practice for business operators.

Core GMP Requirements for Recycled Plastic Food Contact Materials

Quality Management System

Quality management encompasses both quality assurance (QA) and quality control (QC) systems.

A QA system should provide adequate confidence that a company’s recycled plastic complies with Regulation (EU) 2022/1616. This means the system must reliably control risks and ensure consistent product quality throughout the recycling process.

An effective QC system is also crucial to monitoring, and identifying potential failures in, GMP, and defining corrective actions and future preventive actions when relevant.

Documentation

Recyclers’ QA systems must be fully documented in a structured, written format that enables uniform interpretation, implementation, and traceability. As appropriate, documentation should include policy statements, procedures, manuals, records, and traceability measures.

Under Regulation (EU) 2022/1616, specific documentation requirements include:

a. A quality policy manual that defines:

• Quality objectives;
• Organisational structure and responsibilities; and
• Managerial authority for decisions affecting recycled plastic manufacturing.

b. QC plans covering all operations influencing plastic quality, including:

• Input material and recycled plastic characterisation;
• Supplier qualification;
• Individual unit operations in the recycling process; and
• Critical control points relevant to recycled plastic quality.

c. Process monitoring and control procedures, including:

• Inspection and QA techniques; and
• Critical limits for each quality‑relevant point in the process.

d. System effectiveness monitoring, including:

• Methods for evaluating the QA system’s ability to achieve required recycled plastic quality; and
• Processes for handling non‑conforming products.

e. Testing and analytical protocols, including:

• Tests conducted before, during, and after production;
• Testing frequency; and
• Calibration of testing equipment with appropriate traceability.

f. Recording systems: all records necessary to demonstrate control, traceability, and compliance.

Quality Assessment Stages

Lastly, QA systems must include designated quality assessment stages: mandatory assessment points in the recycling process. At these stages, recyclers must evaluate each batch of material from a manufacturing stage to verify compliance with critical limits defined in internal risk assessment at each relevant unit operation. Additionally, recyclers are required to confirm that the materials meet predefined output quality criteria, using relevant tests and evidence.

In each assessment stage, each batch must be formally assessed and categorised as:

• Compliant and suitable for further processing;
• Requiring corrective action before further processing; or
• To be discarded or diverted to non‑food applications.

On a Glance: Navigating the Requirements

The regulatory environment for plastics recycling is complex and frequently evolving. Under Regulations (EC) 2023/2006 and (EU) 2022/1616, recyclers must:

• Operate a robust, documented, GMPbased quality system;
• Maintain clear responsibilities, testing protocols, and traceability;
• Control and monitor all recycling operations, including control points and critical control points;
• Implement mandatory quality assessment stages for batch‑level compliance decisions; and
• Keep full records and ensure traceable calibrations and analytical evidence.

Intertek’s global network of experts supports business operators in interpreting and implementing GMP system requirements and meeting applicable regulatory obligations across recycling processes.  We’re here to help!