FSSAI Issues Guidelines for Use of Recycled PET in Food Packaging

The notification, dated May 23, 2025, outlines the scope, definitions, process requirements, acceptance criteria, marking and labeling, documentation, and authorization procedures for transforming post-consumer PET into FCM-rPET resins suitable for food contact materials.

Key aspects of the guidelines include

The guidelines apply specifically to the recycling of post-consumer PET used for food applications into FCM-rPET resins. It covers the acceptance criteria for using FCM-rPET in food contact materials and applies only to recycling technology approved by FSSAI. It does not cover the production of resins for non-food applications.

The guidelines define key terms such as Virgin PET (vPET), Post-Consumer food grade PET, PET Resin, and Recycled Polyethylene terephthalate (FCM-rPET), emphasizing that FCM-rPET must undergo a validated decontamination process to achieve specified purity for direct food contact.

The guidelines specify four acceptable recycling processes:

  1. Super-Clean Recycling Process
  2. Melt-in Recycling Process
  3. Paste-in Recycling Process
  4. Chemical Recycling Process (with specific application requirements) Conventional mechanical recycling without a decontamination step is explicitly disallowed for manufacturing food contact materials.

The guidelines detail requirements for process input, process validation (including challenge and migration tests), process output monitoring (including extraction and migration tests, and sensory analysis), and process operation & management, emphasizing Good Manufacturing Practices and quality assurance programs.

As referred in the process validation and output sections of the guidelines.

Food Contact Materials made of FCM-rPET resin must carry a specific symbol indicating the use of recycled PET along with the percentage used and a statement clarifying that the packaging material is made with recycled PET. Compliance with other national regulations for marking and labeling is also required.

FCM-rPET manufacturers, converters, beverage bottlers, food packers, and FBOs must maintain and provide relevant documentation, including a Declaration of Compliance, Regulatory Opinion (NOC/NOL), and supply chain records.

Manufacturers intending to produce FCM-rPET must apply for authorization from the Food Authority by submitting necessary information as per a specified form. The manufacturing plants will also be subject to annual audits. The FSSAI will either authorize or reject the application and will maintain a list of authorized manufacturers on its website.

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