A collisional-radiative non-equilibrium impurity treatment for JOREK 3D nonlinear magneto-hydrodynamic (MHD) simulations has been developed. The impurities are represented by super-particles flowing along the fluid velocity field lines, while ionizing and recombining independently according to ADAS data and local fluid density and temperature. The non-equilibrium impurity contributions are then projected back to the fluid field for self-consistent time evolution. A 2D test case is used to compare the new non-equilibrium impurity model against previous Coronal Equilibrium (CE) impurity treatment, as well as to compare the non-equilibrium impurity behavior between the single and the two temperature model. Further, we conduct benchmark with previously published coronal non-equilibrium results by other 3D nonlinear MHD codes such as M3D-C1 and NIMROD. The new non-equilibrium treatment is shown to successfully capture the early phase cooling by weakly ionized impurities which the CE model missed. The benchmarks with M3D-C1 and NIMROD show general agreement in both the integrated quantities and the 2D profile evolution, despite the difference in the atomic model used. The above comparison and benchmark cases demonstrate the capability of the non-equilibrium impurity model for JOREK, paving the way for more sophisticated 3D non-linear Massive Material Injection (MMI) simulations which have important applications in disruption mitigation studies.