The problem
Symptom. A buyer queries a 28,000-tray order because the converter claims 30 % recycled content by mass balance, while the food-contact layer uses only physically segregated rPET from an unlisted process.
What it costs. With no calculation basis or authorised process named in the order, the claim cannot be verified, the batch is held at goods-in and the traceability file has to be rebuilt.
This article separates physical segregation from mass balance, gives EN 15343 and (EU) 2022/1616, and sets the clause that fixes the declared percentage and its basis.
- 1. When a 30 % recycled-content claim cannot be checked
- 2. Ask for the mass-balance or segregation declaration
- 3. EN 15343 traceability and (EU) 2022/1616
- 4. Why food-contact rPET needs an authorised process
- 5. Write the percentage and calculation basis into the order
- 6. Recovery actions ranked by cost
When a 30 % recycled-content claim cannot be checked
A buyer queries 28,000 thermoformed trays because the converter claims 30 % recycled content by mass balance, while the layer that touches the food uses physically segregated rPET from a process not named in any authorisation. The percentage is plausible but its basis is undefined.
| What the buyer sees | Document behind it | First clause to check |
|---|---|---|
| 30 % recycled, basis not given | Calculation method undefined | Physical segregation or mass balance named |
| rPET process not listed | Food-contact authorisation missing | (EU) 2022/1616 process evidence |
| No chain-of-custody record | Traceability gap | EN 15343 records per lot |
| Old 282/2008 cited | Superseded regulation | (EU) 2022/1616 named |
Table 1 - Reading a recycled-content gap before booking the lot
Ask for the mass-balance or segregation declaration
Request a recycled-content declaration stating the percentage by mass, the calculation basis, the traceability standard and the recycling process behind the food-contact layer. A single '30 % recycled' line cannot show whether the figure is segregated material or an allocated mass-balance credit.
A five-step diagnostic sequence
- Read the claim.
A '30 % recycled' line must state whether it is by mass and how it was calculated. - Name the basis.
Distinguish physical segregation, where feedstock stays identifiable, from an allocated mass-balance credit. - Check the standard.
EN 15343 governs traceability and the calculation of recycled content for plastics. - Verify food-contact use.
Any rPET in the contact layer needs an authorised recycling process under (EU) 2022/1616. - Bind it in the order.
State the 30 %, the basis, EN 15343 and the sheet supplier, and note (EC) 282/2008 is replaced.
The chart below is a typical result from that measurement step. Use it to separate a design limit from a setting that can still be recovered.
EN 15343 traceability and (EU) 2022/1616
EN 15343 sets the traceability and conformity framework for recycled plastics and the calculation of recycled content by mass. Regulation (EU) 2022/1616 requires food-contact recycled plastic to come from an authorised process, and replaced the older Regulation (EC) No 282/2008.
| Clause or parameter | Required value | What goes wrong outside it |
|---|---|---|
| Declared recycled content | 30 % by mass, basis stated | A credit quoted as physical material |
| Calculation basis | Physical segregation or mass balance | Two methods mixed in one figure |
| Traceability standard | EN 15343 records per lot | No chain of custody on file |
| Food-contact rPET | Authorised process under (EU) 2022/1616 | An unlisted process in the contact layer |
Table 2 - Recycled-content clauses for the tray drawing and order
Physical segregation keeps the recycled feedstock identifiable through the chain of custody, while mass balance allocates a credit across a mixed stream and must be declared as such. For a food-contact tray the finished article still has to meet the 10 mg/dm2 overall migration limit of (EU) 10/2011.
| Azione | What it fixes | Cost or trade-off |
|---|---|---|
| Obtain the recycled-content declaration | Closes the paperwork gap | Low: a supplier document request |
| State the calculation basis | Makes the 30 % reproducible | Low: an order clause |
| Reconcile EN 15343 lot records | Restores traceability | Medium: a records review |
| Replace unauthorised food-contact rPET | Clears a genuine authorisation gap | High: requalification and a re-run |
Table 3 - Recovery actions ranked by cost
Write the percentage and calculation basis into the order
On the order state the declared percentage by mass, name physical segregation or mass balance as the calculation basis, cite EN 15343 and require evidence of an authorised process under (EU) 2022/1616 for any rPET in the food-contact layer. Bind the sheet supplier and lot records.
Want the tray checked against your line?
Send us the tray drawing and the line conditions. We will flag the geometry and material choices that cause jams, and quote a tool with an acceptance test.
What to send us
- Tray drawing with draft and radii
- Sheet grade and gauge
- Stack depth and line speed
- Drawings of the magazine or denester
Recovery actions ranked by cost
For a held batch, first obtain the declaration and its calculation basis; paperwork is the cheapest fix. Then reconcile the chain-of-custody records under EN 15343, and only an unauthorised food-contact process forces replacement with compliant material, the costliest route.
Before you sign off this thermoformed tool
- The order states the declared recycled content as a percentage by mass, here 30 %, not a vague 'recycled' label
- The calculation basis is named as physical segregation or mass balance, not left to the supplier
- EN 15343 traceability and conformity records are required for every delivered lot
- Any rPET in the food-contact layer is backed by an authorised process under (EU) 2022/1616
- Regulation (EC) No 282/2008 is recognised as superseded rather than cited as current evidence
A tray that looks right in the carton can still stop a filling line. Test the stack, not a single part.
Why was a 30 % claim queried?
It gave no calculation basis. A mass-balance credit and physically segregated feedstock are different figures, so the buyer cannot reproduce the percentage.
What is the difference between the two bases?
Physical segregation keeps the recycled feedstock identifiable through the chain of custody; mass balance allocates a credit across a mixed stream.
Which standard covers traceability?
EN 15343 sets the framework for plastics recycling traceability, conformity and the calculation of recycled content by mass.
What does (EU) 2022/1616 require?
Recycled plastic intended for food contact must come from an authorised recycling process; it replaced Regulation (EC) No 282/2008.
Does a recycled claim change migration compliance?
No. The finished tray still has to meet the 10 mg/dm2 overall migration limit of (EU) 10/2011, irrespective of the declared content.
Who owns the declaration?
Put it in the order: the 30 %, the named basis and EN 15343 make it a document check. The shares in Figure 1 are illustrative engineering guidance for diagnosis, not a measured survey; confirm them on your own line.
Get a tray that runs on your filling line
Send us the tray drawing or a sample stack. We will review draft, trim and material, then quote a production tool with a measurable line-acceptance test written into it.
To get an accurate quote, send:
- Tray drawing or sample stack
- Sheet material and gauge
- Line speed and denesting method
- Annual volume and target unit price
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