Is PolyAl food-contact safe? EU Regulation 2022/1616 explained
Why PolyAl is currently restricted to non-food-contact applications and what it would take to change that.
Short answer: no — PolyAl from post-consumer beverage cartons is not approved for direct food contact in the European Union under Regulation (EU) 2022/1616. This article explains why, and what manufacturers can and cannot do today.
The legal framework
Regulation (EU) 2022/1616 of 15 September 2022 governs recycled plastic materials intended to come into contact with food. It replaces Regulation 282/2008 and sets a strict authorisation regime: every recycling process for food-contact applications must be evaluated by EFSA and authorised by the European Commission.
What is allowed today
- Mechanical recycling of PET from food-grade input (well-established route, hundreds of authorised processes)
- Closed-loop recycling under specific authorised processes
- Behind-a-functional-barrier uses, where the recycled layer never touches the food
Why PolyAl does not qualify (yet)
- Mixed input stream: post-consumer cartons may carry trace contaminants from non-food cartons or downstream contamination during collection.
- Polyethylene matrix from non-food-grade source: unlike PET bottles collected through deposit schemes, PolyAl PE has not been authorised by EFSA.
- No EFSA opinion has been issued for PolyAl recycling processes as of 2026.
What PolyAl is approved for
Non-food-contact durable goods: pallets, crates, profiles, urban furniture, decking, fencing, planters, bins, construction elements. PolyAl is also fully compatible with industrial cleaning chemicals (UNE 56875:2021).
The future
Mechanical-only PolyAl will likely remain non-food-contact. Solvent-based routes (selective dissolution-precipitation, SDP) that fully purify the polyethylene fraction may eventually qualify, but no EFSA dossier is currently public.