On April 15, 2026, the European Union submitted a draft amendment to Regulation (EU) 2022/1616 to the World Trade Organization (WTO). This draft amendment introduces new Declaration of Compliance (DoC) requirements, restructures the management model of the EU Register, and establishes more detailed rules for the customs clearance of imported recycled plastic articles.
Background
The current Regulation (EU) 2022/1616 establishes the rules for the recycling, manufacturing, and placing on the market of recycled plastic materials and articles originating from waste plastic.
This amendment aims to address existing bottlenecks in documentation and supply chain oversight. By introducing a digital management platform and a more refined document classification, it ensures that every batch of recycled plastic articles entering the EU market can be traced back to its collection and decontamination sources.
Key Highlights
Compared to the current regulation, the draft proposes several substantive regulatory upgrades, with key changes as follows:
1. Introduction of Two New Types of Declarations of Compliance (DoC)
Building upon the existing declarations for recyclers (DoC A) and converters (DoC B), two new types of declarations have been added:
DoC P: Applicable to partially pre-treated plastic inputs or untreated plastic inputs.
DoC C: Applicable to recycled plastic materials and articles whose composition is not expected to undergo further changes in subsequent processing stages.
For food business operators using recycled plastics to package food, the obligation to provide a DoC to retailers may be exempted provided they supply the necessary information and instructions (e.g., via labeling), thereby easing the burden at the end of the supply chain.
Overall, through this amendment, the EU will establish a highly defined supply chain transmission mechanism: Waste Pre-treaters (DoC P) → Recyclers (DoC A) → Converters (DoC B) → Final Product Manufacturers/Packagers (DoC C).
Operators at each stage must ensure that, when issuing their respective declarations, they properly retain the declarations and supporting documents from the preceding stage, readily available for review by competent authorities at any time.
2. Strengthening of Import Controls
To prevent non-compliant products from entering the EU, the draft stipulates that imported products containing recycled plastics (particularly PET materials, bottles, sheets, tableware, and kitchenware) must be accompanied by the corresponding DoCs upon application for release for free circulation at customs. The annex to the draft explicitly defines the Combined Nomenclature (CN) codes for these targeted products.
3. Digital Transformation of the Registration System
The EU’s current public register model will be replaced by a non-public electronic registry accessible specifically to competent authorities and operators.
The registration statuses for decontamination installations have been significantly expanded and clarified into seven specific categories: ‘newly registered’, ‘being established’, ‘active’, ‘inactive’, ‘suspended’, ‘audit pending’, and ‘decommissioned’. This categorization reflects various scenarios across the full lifecycle of the facilities, thereby enhancing regulatory transparency.
4. Clarification of Testing Method Requirements
The draft references ISO 12418-2:2012 (Annex A)—or methods yielding equivalent or better performance—as the standard method for verifying the specifications of post-consumer physically recycled (PCR) PET.
Impact Analysis and Recommendations
For businesses in the industry, the changes brought about by the EU’s draft amendment on recycled plastics will have a profound impact on core areas such as supply chain management, compliance processes, and quality control.
In response, REACH24H Consulting Group advises relevant enterprises to:
Review Supplier Structures: The introduction of DoC P and DoC C defines the compliance responsibilities of the upstream supply chain (including partial pre-treatment service providers). Enterprises should proactively map their supplier structures now, push upstream suppliers to provide the newly required declarations (P or C), and preemptively mitigate supply chain compliance risks.
Monitor System Updates: The EU's planned rollout of a non-public electronic registration system paired with a granular facility status tracking framework—while not yet formally unveiled—will deliver unprecedented transparency in compliance data. An installation’s system status will directly dictate whether a company can continue supplying the EU. Enterprises should pay close attention to the development progress and technical interface requirements of the EU electronic registry.
Implement Strict Document Management: The introduction of new testing methods and traceability requirements will inevitably increase compliance costs. Beyond fulfilling performance verification according to the new standards, companies must establish robust document management and transmission protocols.
The deadline for the public consultation period on this draft amendment is June 14, 2026. According to the current timeline, the regulation is expected to be adopted on September 30, 2026, and will officially enter into force on the 20th day following its publication in the Official Journal of the European Union.
Given the continuous tightening of EU regulations governing recycled plastic food contact materials, affected entities are advised to closely track the latest legislative progress and regulatory developments to ensure the stable and compliant operation of their export businesses.
If you have any questions or require professional consultancy services, please feel free to contact us at customer@reach24h.com.
