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Mono-material film standards: regulations, certifications and the documents that prove compliance

Mono-material film standards fall into two separate layers. The first is law: the PPWR and the EU food-contact rules for plastics. The second is voluntary industry standards: RecyClass, CEFLEX and the ISO framework. This page maps what each one proves and which documents should accompany a film structure.

RecyClass v3.1 (August 2025) uses three classes: A, B and C. Classes D, E and F were removed from the methodology in March 2025. The PPWR, Regulation (EU) 2025/40, also defines three performance grades, A, B and C, in Annex II, Table 3. Below 70%, packaging is considered not recyclable and is banned from the EU market from 2030. The two systems are aligned, but not numerically identical. The binding legal criteria arrive by delegated acts due 1 January 2028, built on the CEN EN 18120 series.

A mono-material film can still fail in practice. A PE/PE structure with incompatible adhesives or carbon-black inks will be rejected at sorting, regardless of its single polymer. The component thresholds and the practical design rules are covered on the design for recycling page. Where food contact applies, the structure comes with a Declaration of Compliance under Regulation (EC) No 1935/2004 and Regulation (EU) No 10/2011.

Summary: the standards that apply

Standard	Type	What it proves	Mandatory
PPWR (EU) 2025/40, grades A, B, C	EU law	Recyclability by design; below 70% banned from 2030	Yes
Regulation (EU) No 10/2011 + amendment 2025/351	EU law	Food-contact safety for plastics	Yes
EN 18120 series (from April 2026)	CEN standard	Normative design-for-recycling framework; Part 13 covers PE and PP flexible film	Reference for the delegated acts
RecyClass v3.1 (August 2025)	Voluntary	Recyclability of the finished packaging; classes A, B, C	Contractual for some retailers and EPR schemes
CEFLEX D4ACE Phase 2 (September 2025)	Voluntary	Component compatibility with the PE and PP streams	Industry reference
ISO 15270:2008	Voluntary	Terminology and test methodology for plastics recycling	Laboratory reference
ISO 22000	Voluntary	Food-safety management of the production process	De facto industry standard

RecyClass certification: who can request it

RecyClass certification involves testing at an independent accredited laboratory. Both the film producer and the brand using the finished packaging can request it. The producer can have a specific structure assessed and pass the certificate to its customers. The brand can independently certify the finished pack, including the film, inks, adhesive and any elements added in conversion. The certificate is issued for the complete material combination, not for the film in isolation. A free self-assessment on the RecyClass Online Tool is not equivalent to formal certification, and the two should not be presented as interchangeable in compliance files.

EU food-contact compliance: Regulation 10/2011 and amendment 2025/351

Regulation (EU) No 10/2011 governs plastic materials in contact with food. It includes the positive list of authorised substances, an overall migration limit of 10 mg/dm² of surface (60 mg/kg of food), and specific migration limits for the restricted substances in Annex I. Amendment 2025/351, in force since 16 March 2025, strengthens purity requirements and covers multi-layer structures explicitly. New products must comply from 16 September 2026.

The food-contact Declaration of Compliance identifies the material and confirms conformity with 10/2011 in the post-16 March 2025 version. It states the restricted substances, the migration limits, the food simulants used in testing and the conditions of use covered: temperature, contact time, food type. It is a separate document from the PPWR Declaration of Conformity, which is required from 12 August 2026 for every packaging type.

ISO 15270 and ISO 22000: what each one certifies

ISO 15270:2008 sets the terminology and evaluation criteria used in plastics recycling. It does not certify individual products; it is the reference framework for the laboratories that issue recyclability reports. ISO 22000 certifies the production process, through HACCP-based controls in extrusion, lamination, printing and die-cutting. Neither certifies the film itself.

The documents to request from a mono-material film supplier

For food packaging, three documents are mandatory. First: the Declaration of Compliance under 10/2011, in the post-16 March 2025 version. Second: the conformity certificates for the raw-material granulates. Third, where the film touches the food directly: the migration report on the relevant simulants.

For PPWR compliance and retailer requirements, ask for four things. The technical data sheet of the structure, with the polymers, adhesive type and quantity, ink pigments and functional elements. A RecyClass assessment or a self-assessment against the CEFLEX D4ACE guidelines. The producer’s ISO 22000 certificate. The PFAS-absence declaration, mandatory for food contact from 12 August 2026. A supplier that cannot produce these documents on request is not yet positioned to support a PPWR-compliant launch.

Beyond the documents, four technical questions are worth asking before an order. Are carbon-black pigments excluded from the inks? Does the adhesive stay below 5% of the finished pack weight? What is the film density, relevant for NIR sorting? Does the structure contain EVOH and, if so, what share of the total mass?

The thresholds and grades these documents must support are covered on the PPWR recyclability grades page.

Frequently asked questions

Who can request RecyClass certification: the film producer or the brand?

Both can. The producer can have a specific structure assessed and pass the certificate to its customers. The brand can independently certify the finished pack, with the film, inks, adhesive and elements added in conversion. The certificate covers the complete material combination, not the film in isolation.

What must a food-contact Declaration of Compliance contain?

The identification of the material and the article, plus confirmation of conformity with Regulation (EU) No 10/2011 in the applicable version, post 16 March 2025. Then the restricted substances and migration limits, the food simulants used in testing, and the conditions of use covered: temperature, contact time, food type.

What is the deadline for the food-contact amendment 2025/351?

New products must comply from 16 September 2026. The amendment took effect on 16 March 2025 and strengthens purity and traceability requirements for plastics in food contact.

Does ISO 22000 certify the film itself?

No. It certifies the production process, including hazard controls and traceability, not the material composition on its own.

Is the food-contact Declaration of Compliance the same as the PPWR Declaration of Conformity?

No. They belong to different regulations. The Declaration of Compliance covers food-contact safety under Regulation (EU) No 10/2011. The PPWR Declaration of Conformity covers the packaging’s sustainability requirements under Regulation (EU) 2025/40, from 12 August 2026. Food packaging usually needs both, and neither replaces the other.

The standards are public; the data behind your packaging is not

If your packaging is built on VLM Poliplast structures, the documentation behind it comes with the supply: technical data sheets, material declarations and recyclability assessments on the current industry reference frameworks, per structure. This is the compliance information suppliers are required to provide under Article 16 PPWR, not a consultancy service.

Contact our technical team

Design for recycling The PPWR Declaration of Conformity

VLM Poliplast supplies compliance documentation for the structures it delivers to its clients.

+40 744 624 924 | office@vlmpoliplast.ro