Navigating the Challenges of Using Recycled Plastics in Food Contact Materials

Consumer CompactHardgoodsJuly 03, 2025

Food packaging is increasingly reliant on plastic. Its durability, versatility and cost-effectiveness make it an ideal solution for a range of food contact products, from water bottles to disposable cutlery. However, plastic pollution is a growing concern and manufacturers face pressure to find sustainable alternatives while remaining compliant with regulations. What viable solutions exist to balance safety, sustainability and regulatory compliance?

The Organisation for Economic Co-operation and Development (OECD) predicts a dramatic rise in annual virgin plastic production over the next two decades. Production is projected to increase by 70% by 2040, from 435 million tonnes (Mt) in 2020 to 736 Mt. Inadequately disposed plastic waste is also projected to grow, increasing from 81 Mt to 119 Mt over the same period. Additionally, plastic leakage into the environment is expected to rise by 50%.¹

Recycling plastic into new products must play a key role in addressing this issue. Not only will it reduce the environmental impact of plastic production and waste, but it will also support global efforts to transition toward a circular economy.

Contamination risks

The idea of ‘use, recycle, re-use’ is appealing, but there are several risks associated with the recycling of plastics, particularly for food contact materials. While monitoring supply chains from raw material to finished product is feasible with virgin plastic, traceability and contamination control become significantly more complex when using recycled materials.

Using recycled plastic in food contact materials introduces the risk of contamination, such as:

Non-food-grade plastics entering the recycling system
Residual chemicals from previous uses (e.g. solvents, inks, adhesives)
Microbiological contamination due to inadequate cleaning
Heat-induced degradation of plastic products

Recycling can amplify contamination risks as, each time the plastic is recycled and reused, pollutants can accumulate in the material. Harmful substances, such as endocrine disruptors and carcinogens, could migrate into food or beverages, potentially posing long-term health risks.

Regulatory landscape

Governments worldwide are stepping up their efforts to regulate plastics in food contact materials, while also continuing to promote circular economic models.

On October 10, 2022, the European Union (EU) enforced Regulation (EU) 2022/1616, which governs the use of recycled plastic materials intended for food contact. It establishes rules to ensure recycled materials meet the same safety and quality standards as virgin plastic. Only suitable, authorized recycling processes, such as post-consumer mechanical PET recycling, are permitted.

The authorization process includes:

Pre-application submission
Submission and completeness check
Information required by the European Food Safety Authority (EFSA) includes:

Administrative dataPublic summary of dossier
Public summary of dossier

Technical dossier, with details of the recycling process, challenge test results, decontamination efficiency, operating parameters and self-evaluation
Risk assessment
Post-adoption – products must carry a declaration of conformity (DoC) and conform to labeling requirements

The EU has also enforced Directive (EU) 2019/904, commonly known as the Single-Use Plastic (SUP) Directive, which aims to reduce the environmental impact of certain plastic products. It aims to ensure that 77% of PET bottles are collected by 2025 and 90% of all plastic bottles by 2029. A packaging and packaging waste regulation will also seek to boost closed-loop recycling and introduce recyclability grades.

At the national level, several European countries are also introducing more stringent legislative requirements. Through its AGEC law, France is targeting 100% recycled plastic in packaging by 2025. In the UK, the plastic packaging tax (PPT) will incentivize the use of recycled materials by setting a £223.69 tax on plastic packaging made or imported into the UK with less than 30% recycled plastic.

In the US, several legislative initiatives are also promoting sustainable plastics, including:

Rewarding Efforts to Decrease Unrecycled Contaminants in Ecosystems (REDUCE) Act – introduces a federal excise tax on virgin plastic resin
California – Public Resources Code (PRC) – targets truth-in-labeling for recyclability and imposes a mandatory recycled content for plastic beverage containersNew Jersey – Recycled Content Law (PL 2021, c. 391) – mandates a minimum recycled content level for rigid plastic containers, plastic beverage bottles and plastic carryout bags

To assist manufacturers, the US Food and Drug Administration (FDA) operates a voluntary No Objection Letter (NOL) program. The application process evaluates whether recycled plastic can be safely used in food contact materials and is available for all plastic types.

Applicants must provide:

Description of the recycling process
Description of the process steps
Challenge test report
Proposed conditions of use

The challenge test involves:

Sampling – substantial quantity of plastic flakes is selected
Contamination – plastic flakes are submitted to a surrogate contaminant cocktail under specified conditions
Contaminant detection – sample tested for contamination
Recycling – sample goes through the recycling process
Contaminant detection – sample is evaluated to see if it meets acceptable residue levels

If the FDA determines the process meets safety criteria, it will issue the NOL. This confirms that recycled plastics can be safely used in food contact applications and supports industry sustainability goals.

The way forward

The question is no longer about avoiding the use of recycled plastics in food contact materials, but how to use them safely, effectively and in compliance with regulations.

SGS solutions

We offer comprehensive testing and certification services to help plastic recyclers and food contact plastic manufacturers comply with evolving regulatory and market demands. Our one-stop solution includes support for both EFSA and FDA NOL applications, along with consultation services, factory audits, document preparation and DoC/label reviews.

As part of our service offerings, we can conduct challenge tests to ensure that recycled materials comply with EFSA's safety standards for food contact plastics and the requirements for NOL application to the FDA.

Learn more about food contact materials.

IMPACT NOW for sustainability

The IMPACT NOW for sustainability initiative brings together all our sustainability solutions under four strategic pillars: climate, nature, ESG assurance and circularity. Under the IMPACT NOW circularity pillar, we provide practical solutions to reduce dependence on virgin plastics while improving recyclability and promoting circular systems. Together, we empower businesses to drive meaningful change and meet growing regulatory and stakeholder demands. This ambitious initiative underscores our commitment to a climate-neutral, nature-positive and pollution-free future.

Learn about IMPACT NOW for sustainability.