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RulesOf.EU
Regulation (EU) 2022/1616 · Annex III ·Applies since 10 October 2022

The food-contact declaration that is a form, not a list

Recycled plastic intended to come into contact with food needs a declaration of compliance under Regulation (EU) 2022/1616, and Article 29 does not describe it — it hands you a template. Annex III sets out two: Part A for recyclers, Part B for converters whose plastic contains recycled plastic. This free tool prints both, line for line, in each of the 22 languages, in the Regulation's own wording. It does not test your material, and it does not decide whether it complies.

Which of the three this is

Three Regulations carry a declaration under Article 16 of Regulation (EC) No 1935/2004, and they do not all work the same way. Two prescribe content — a numbered list of what the declaration must say, with no form to follow: Regulation (EU) No 10/2011 for plastics, and Regulation (EC) No 450/2009 for active and intelligent materials. The third prescribes a form — Regulation (EU) 2022/1616 for recycled plastic, whose Annex III is a template with numbered sections, boxes to tick and a signature block. This page is the third: what you fill in below is the act’s own form.

Recycled plastic is not outside Regulation (EU) No 10/2011 — this Regulation adds rules on top of it, and a recycled plastic material needs the Annex IV declaration as well. The food contact plastics page produces that one.

Which template

Three things on this page are ours, not the annex's: the switch between Part A and Part B, the button that adds a row to the list of added substances in Part B point 3.2.5, and this note. Everything else is Annex III's own wording, including the column headings of both tables and the whole of Section 4 — which is why this is the one page in this family that shows you a signature block. The two labels beside the boxes in Part B point 2.1.6 drop a leading pair of box glyphs that the Official Journal prints twice; the words are unchanged.

RECYCLERS DECLARATION of COMPLIANCE with REGULATION (EU) 2022/1616

I, the undersigned, declare in name of [ADD NAME OF RECYCLER] as identified in Section 1.1, that the recycled plastic material identified in Section 1.2 was produced in accordance with Regulation (EU) 2022/1616. The recycled material to which this declaration applies is suitable for use in contact with food, provided it is used in accordance with the restrictions set out Section 3 of this declaration, and with the instructions in this declaration and with the labelling on the product.

Hereby I declare that the contents of this declaration is correct to the best of my knowledge and in compliance with Regulation (EU) 2022/1616.

Section 1: Identification

1.1 Recycler

1.2 Recycled product

1.3 Competent authority

Section 2: Compliance

2.1 Basis for authorisation or permission to operate (tick one box only)

2.2 Results of compliance assessment as listed in the compulsory quality assessment stages in Table 3.1 of Annex II; compulsory only if 2.1.1 ticked

Important: Fields 2.2.2 to 2.2.4 may be left blank, provided field 2.2.5 is ticked

StageDecision criteria and outcome(s)Batch Number(s)
2.2.1 Exit
2.2.2 Entry
2.2.3 Input
2.2.4 Output

Section 3: Instructions and information to users of the product

Instructions to converters

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Instructions to users further down the supply chain, including end users

Section 4: Signature

The declaration

Annex III prescribes a template, and that makes this page the odd one out. Its two siblings under Article 16 of Regulation (EC) No 1935/2004 list what a declaration must contain and leave its shape to you. Article 29(1) and (3) of this Regulation say the declaration is provided in accordance with the description and template set out in Part A or Part B of Annex III. So there is a model here, and reproducing it is the point: four numbered sections, eighty-five numbered fields, eleven boxes and a signature block.

Part A or Part B, not both. Part A is issued by the recycler for the recycled plastic it places on the market; Part B by the converter whose converted plastic contains recycled plastic. The switch above the form chooses which template you are filling in, and the two are not interchangeable — Part A carries the compliance-assessment stages, Part B carries the actual recycled content and what goes to users further down the chain.

What the boxes mean is the act's instruction, not ours. Point 2.1 of Part A says tick one box only, so those four are a single choice; point 3.2.1 of Part B says tick as applicable, both may apply, so those two are not. Point 2.2 of Part A adds that fields 2.2.2 to 2.2.4 may be left blank provided 2.2.5 is ticked — and 2.2.5 is a promise to produce that information within three working days, not a way of not having it.

What is not here. Article 30 requires the recycler and the converter to hold the supporting documentation — the compliance assessment, the monitoring records, the evidence behind what the template says — and to make it available to the competent authority. That is a separate obligation from this document, and no generator can produce it: it is your data.