Codex considers global guidelines for recycled plastics in food packaging

The Codex Alimentarius has published a discussion paper proposing the development of international guidelines for the safe use of recycled plastics in food packaging. Prepared by the United States with the collaboration of Canada, the European Union, and Japan, the document addresses a rapidly shifting global packaging landscape. With multiple countries enacting laws that mandate minimum recycled content and consumer brands making public pledges to increase sustainability, the demand for recycled packaging materials has surged significantly.

The paper outlines that while materials like metal and glass are largely impervious to contaminants, recycled plastics and paper present unique food safety challenges because they are far more susceptible to contamination. If not carefully managed, recycled plastics can introduce unauthorized chemical components, degradation byproducts, and unknown substances from prior consumer or industrial use through migration into foods and beverages. The document emphasizes that because predicting specific contaminants from variable source waste is difficult, control programs must focus on source management, waste stream segregation (differentiating between low-contamination industrial scrap and high-contamination post-consumer curbside waste) and rigorous cleaning validation methods such as challenge testing. Furthermore, the global regulatory framework remains fragmented, with stark differences in how nations oversee recycled food contact materials.

This discussion paper will be evaluated at the 19th meeting of the Codex Committee on Contaminants in Foods (CCCF), scheduled in Cairo, Egypt, for October 19–23, 2026. At this session, delegates will decide whether to formally move forward with drafting the global guidelines.

On October 5, 2026, the Food Packaging Forum (FPF) submitted official feedback on the proposal through the European Consumer Organisation (BEUC). While FPF welcomes the objective of supporting safe circularity, it argues that several scientific and implementation challenges require deeper discussion first. FPF's feedback centers on four main topics.

First, FPF points out that chemical migration is a well-documented phenomenon across many food contact materials and is not restricted to recycled plastics alone. Although recycling increases chemical complexity, similar safety concerns emerge in primary plastics, paper, and aluminum.

Second, FPF questions why the initiative narrows its focus solely to recycled plastics when the initial Codex proposal covered recycled materials more broadly, noting a complete lack of justification for omitting other non-inert materials like paper.

Third, FPF highlights significant regulatory and analytical hurdles in proving the chemical safety of both primary and recycled plastics, particularly regarding non-intentionally added substances (NIAS) and the practical inability to fully characterize every chemical present in recycled plastics.

Finally, FPF notes that the discussion paper fails to explicitly define food safety, urging clearer parameters regarding which specific health outcomes and hazards the guidelines intend to address.

The submission concludes that further scientific dialogue is necessary prior to establishing global guidance for recycled plastics and other non-inert recycled food contact materials. Alongside FPF, various Codex member countries and industry associations submitted online comments.

Sources:

FAO

Food Packaging Forum