EU strengthens traceability of recycled plastic in aquaculture product packaging

From 18 November, businesses packaging fish or other food products in recycled plastic must retain documentation from their suppliers and provide it on request.

The EU has extended the documentation requirements for recycled plastic materials through Regulation (EU) 2026/2376, with the aim of strengthening traceability.

Food businesses using this packaging, including those packaging fish and seafood, will not normally have to pass on a declaration of compliance to retailers or distributors supplying retailers, provided they give the necessary instructions through labelling or other documentation and ensure that information on recycled content matches the information received from their supplier.

This exemption does not remove the requirement to retain the documentation. If a competent authority requests it as part of an official control, the business must provide it within ten working days. In other cases, it has twenty working days.

The transition has two key dates. Until 18 February 2027, recyclers and converters may place products on the market under the previous rules without updating their declarations of compliance.

The deadline is extended to 18 May 2027 for placing products on the market without the new declarations required during the preparation of plastic for decontamination and at later stages where its composition no longer changes, including the manufacture and use of packaging, where applicable.

Materials and packaging made from products lawfully placed on the market during these transition periods may continue to be marketed until stocks are exhausted.

For aquaculture businesses buying finished packaging, the first practical step is to ask suppliers whether it contains recycled plastic, what documentation accompanies it and what conditions of use apply.

This information will help coordinate purchasing, quality and labelling teams and anticipate possible supply changes.

The rules do not change the food-safety principle that recycled plastic must meet EU requirements for use in contact with food. Among other things, the amendment clarifies conformity documentation and traceability throughout the supply chain.