Posted: 18/09/2025

Joint FSA, RECOUP & BPF Update: Food Contact Regulations

The British Plastics Federation (BPF) and RECOUP have been working with the Food Standards Agency (FSA) and Defra on the implementation of Commission Regulation 2022/1616, covering recycled plastic materials and articles in contact with food. The FSA has now shared a detailed update on progress.

The FSA has confirmed it will act as the competent authority (CA) for England, Wales and Northern Ireland, with arrangements for Scotland still under discussion. Its immediate priority is to establish an auditing scheme for UK plastic recyclers placing food-contact materials on the EU market.

FSA auditors will carry out the required checks, with district councils also undertaking verification audits in Northern Ireland.

Key points include:

  • Audit process and timing: Audits will be carried out in the order applications were submitted to the EU, covering both established and novel recycling technologies. Companies may be contacted for additional information to support the European Food Safety Authority’s evaluation. The European Commission also published a working group paper in May indicating that audit results should be submitted by the end of this year, with a possible extension into 2026.
  • Market access: The FSA does not expect the EU to restrict access to its market while audits are pending, but recyclers are advised to monitor the EU’s draft registers and FCM document library for updates.
  • Ongoing liaison: Recyclers are encouraged to keep the FSA informed of any facility closures, supply copies of EU registration documents, and provide evidence of meeting input-specification requirements under Article 6.

The FSA continues to monitor EU guidance and is in regular dialogue with the European Commission. A longer-term goal remains a UK–EU Sanitary and Phytosanitary (SPS) agreement, but the immediate focus is on completing the first and subsequent audits within the required timeframe.

When checking on CA progress of an EU application or notification, updates can be obtained by emailing recycledplastic-notifications@food.gov.uk. There is currently no online portal to check application status, but applicants can refer to the EU’s draft registers for published information. Limited updates may also be available in the FCMJEGs meeting minutes if a relevant application is discussed, although these will not include commercial details.

Follow this link for more useful information:

Food contact materials authorisation guidance | Food Standards Agency