Maturity Regulation (EU) 2022/1616 · Recycled Plastic Materials in Contact with Food
Your recycled food contact plastic practices, measured against Regulation 2022/1616 and turned into a costed action plan.
10 themes, a 5-level scale. And the action that moves each level to the next.
The framework’s 10 themes, already written from L1 to L5. One company, one business unit, or 300 at once.
Maturity Regulation (EU) 2022/1616 · Recycled Plastic Materials in Contact with Food
10 themes, 5-level scale.
Nordhavn Industries
53 / 100
They measure their maturity with Datamensio
An example
This could be your situation.
Take one company as an example: three sites, three spreadsheets, no shared answer.
Nobody can consolidate.
Nordhavn Industries, 2,400 people in Hamburg, Lyon and Porto. A client asks where the group stands. Each site answers in its own spreadsheet, with its own scales.
Three weeks, a single base.
One Commission Regulation (EU) 2022/1616 of 15 September 2022 assessment launched across all three sites at once, from the managers’ interview notes. The framework was already written, its 10 themes and levels L1 to L5 too.
Two costs avoided before being committed.
A score of 53 out of 100, with the gap concentrated on three themes. The AI companion spotted that two actions duplicated those of another audit. The committee report took one sentence to request.
What it saved them
- 3sites measured on the same base, instead of three questionnaires to reconcile
- 2duplicate actions caught before the spend
- 1committee report, with no manual rework
These figures are an example. They could be yours.
The standard imposes processes. Datamensio says where you stand.
01
The framework is already written
Themes, questions and levels L1 to L5, all written. You do not start from an empty spreadsheet.
02
The score lands the same day
Online, by self-assessment link or in interview. Theme by theme, comparable over time.
03
The gap becomes a costed plan
Every step up carries its action. The AI prioritises on expected effect, not on the order of the standard.
04
Progress can be demonstrated
Campaign after campaign, against your target and against your own past. That is what your board asks for.
The maturity scale
One level, the next, and the action that links the two.
This mechanism, a level, a level above, and the action that connects the two, is what turns an observation into a trajectory.
Does the traceability of recycled plastic inputs allow each batch to be traced back to its origin and its prior food contact use?
- N1
No traceability of inputs. Recycled material is received with no documented information on its origin or prior use.
- N2
Information exists in supplier documents, but it is neither verified nor linked to the batches received. Retrieval depends on a request to the supplier.
- N3
Each incoming batch is recorded with its origin, recycling technology and prior use. Information is verified on receipt under a written procedure.
- N4
Traceability is systematic and supported by tooling: batch by batch link between inputs, recycled material and finished products, tested through documented reconstruction exercises.
- N5
The system is reviewed periodically based on traceability exercises, supplier audits and changes to the Union register, with a documented record of revisions.
Action to move from L2 to L3
Add a mandatory checkpoint to receiving inspection covering the origin, recycling technology and prior use of each batch, record this data in the batch record and validate its completeness during the monthly quality review.
« With Datamensio, we meet our objectives far more efficiently. The ERDF inspection services and our supervising ministry particularly appreciated an approach that gives them reliable data. »
Director, CCI 94CCI Île-de-France
« We believe this is the most suitable solution to scale our transformation project and measure impact according to our needs. »
Maja SucekChief Operating Officer, Interreg Danube
Rarely on its own
Frameworks combine. Put several together to cover your business, or have the AI write yours.
Take your first measurement
What this framework covers
Regulation (EU) 2022/1616 replaced Regulation (EC) No 282/2008 and sets the rules applicable to recycled plastic materials and articles intended for food contact. It is built on a recycling technology logic: only adequate technologies, listed in the Union public register, may be used to produce recycled plastic destined for food contact. The text requires the registration of recycling facilities and converters, traceability of input materials, control of the decontamination process, and the transmission of information along the chain, alongside Regulation (EC) No 1935/2004 and Regulation (EU) No 10/2011.
In practice, the difficulty lies not in reading the text but in mastering the chain. Do you know, for each packaging reference, which recycling technology produced the material and whether it is properly covered by the register? Are your input materials qualified upstream, with documented evidence of their origin and prior food contact use? Do your supplier declarations of compliance actually contain the required information, or are you settling for a dated document nobody rereads? These three questions determine how solid the system really is.
One common confusion deserves clarifying: the regulation does not simply distinguish “authorised” recycled plastic from “prohibited” plastic. It organises several situations, including adequate technologies, technologies under evaluation operating under a transitional regime, and conformity schemes applicable to new technologies under development. Each situation calls for distinct documentary obligations and its own deadlines. Organisations that treat the topic as a simple tick box in the supplier specification expose themselves to gaps during official controls carried out under Regulation (EU) 2017/625.
The maturity assessment answers a different question from a compliance audit. An audit concludes with compliant or non-compliant, for a given scope and date. The assessment places each practice on a progressive scale and points to the action that moves it up a level: qualifying input materials, tracing recycled material batches, structuring analytical monitoring, industrialising the review of declarations of compliance. Datamensio measures maturity and prepares for the audit, it does not issue any certificate.
Within Datamensio, the framework is ready to use and remains adaptable. The AI adjusts the themes, questions and levels to your position in the chain, recycler, converter, filler or distributor, or builds a variant from your own documents, specifications and procedures. The action plan generated from the gap between score and target is grouped by the AI into a prioritised roadmap, which can be consolidated with your other food and beverage assessments.
Reference standard: Commission Regulation (EU) 2022/1616 of 15 September 2022
The themes assessed
Governance and regulatory scope
Identification of recycled materials used, linkage to Regulation 2022/1616 and related texts, roles and responsibilities, monitoring of the Union register and transitional deadlines.
Recycling technologies and conformity schemes
Identification of the technology applied to each material, verification of its status, situation of technologies under evaluation, operating authorisation of the facility.
Operator and facility registration
Registration of recycling and decontamination facilities, declaration of converters, updating of information, availability of evidence for the competent authority.
Input qualification and traceability
Origin of plastic waste, prior food contact use, sorting and acceptance criteria, stream separation, upstream batch traceability.
Control of the decontamination process
Critical process parameters, validation of decontamination efficiency, continuous monitoring, management of deviations and non-conforming batches.
Downstream traceability and chain of custody
Identification of recycled plastic batches, incorporation rates, chain of custody through to the finished material, ability to recall and reconstruct a batch.
Declarations of compliance and documentation
Content and completeness of declarations, consistency with supplier data, transmission of information to customers, retention and archiving.
Analytical monitoring and migration
Control plan, contaminants and non-intentionally added substances, migration limits, choice of laboratories, interpretation and follow-up of results.
Manufacturing and good practice
Alignment with good manufacturing practice for food contact materials, prevention of cross-contamination, management of recipe or supplier changes.
Supplier monitoring and continuous improvement
Audits and assessments of recyclers and converters, tracked indicators, handling of non-conformities, periodic review of the system.
A short version of the framework is available for the online self-assessment.
Frequently asked questions
Can Regulation 2022/1616 be certified?
No. It is a directly applicable EU regulation, checked by competent authorities under Regulation (EU) 2017/625. The Datamensio assessment measures the maturity of your practices and prepares for these controls, it does not issue any certificate.
What is the difference between this assessment and a compliance audit?
An audit concludes with a gap or a compliance finding, at a given date and scope. The assessment places each practice on a maturity scale and points to the action that moves it to the next level. The two complement each other: the assessment builds the trajectory, the audit validates the state.
How long does the assessment take?
The short version can be completed in one working session. The full version, run collaboratively with quality, procurement, packaging and the plant, typically takes one to two weeks, most of the time spent gathering documentary evidence.
Does the framework suit both a recycler and a packaging user?
Yes, provided the scope is adjusted. The AI adapts themes, questions and levels according to your position in the chain, recycling facility, converter or food placer on the market. You can also start from your own procedures.
How does this assessment fit with our other food and beverage frameworks?
Documentation and traceability requirements overlap with Regulation (EC) No 178/2002 and HACCP. A cross-cutting roadmap consolidates several assessments and groups common actions rather than duplicating them per framework.
Can several sites be compared with each other?
Yes. The assessment runs site by site, with a score per theme and a target. The benchmark compares business units against each other and each site against its previous assessments, to identify practice gaps within the group.
Is technical expertise needed to answer?
The questions cover management, traceability and documentation practices, not polymer chemistry. Some questions on decontamination or migration require input from a technical contact or the laboratory: collaborative mode allows these questions to be assigned directly to them.
Where is the data hosted?
In France, with OVH, backed up with Scaleway. No transfer outside the European Union. The AI models used can be selected, including from European providers.