A Recycled-Content Claim Is Not a Food-Contact Safety Case · Europe's 2026 mass-balance accounting rules, beverage-bottle obligations and the unresolved evidence boundary between circularity and chemical safety

The European Union's 2026 packaging transition creates a consequential distinction for beverage manufacturers: the amount of recycled plastic attributed to a bottle is not, by itself, evidence that the material is safe for food contact. Commission Implementing Decision (EU) 2026/1425, published on 3 July 2026, revises the methodology for calculating, verifying and reporting recycled content in single-use plastic beverage bottles, including accounting for recycling routes beyond conventional mechanical PET recycling. At the same time, Regulation (EU) 2022/1616 and the broader food- contact framework retain independent requirements concerning feedstock control, decontamination, migration and traceability. This article examines the resulting interface among mass balance, physical composition, chemical risk and industrial procurement. It compares European obligations with the more fragmented approaches in Great Britain and the United States, and proposes a testable dual-evidence qualification model for packaging specifications. The model is a research agenda, not an authorised certification scheme. The principal conclusion is that circular-content accounting and consumer-safety substantiation must remain distinct, connected and auditable.