FSSAI
The norms cover the acceptance criteria for using FCM-rPET resins in food contact materials and apply only to recycling technology approved by FSSAI.

The Food Safety and Standards Authority of India (FSSAI) has notified guidelines for the use of recycled polyethylene terephthalate (rPET) as food contact material in food and beverage packaging.

The authority has approved validated decontamination processes, acceptable recycling technologies, and strict testing and documentation requirements for compliance to ensure that stringent safety standards are met.

Modifying the Food Safety and Standards (Packaging) Regulations, 2018, FSSAI’s 28 March 2025 amendment had allowed the use of rPET in packaging, storing, carrying, or dispensing food products. “All rPET packaging must comply with relevant national standards or regulations,” the FSSAI notification said.

Union Minister of state for health and family welfare Prataprao Ganpatrao Jadhav recently announced that the guidelines, seen by Packaging South Asia, have been prepared after extensive consultations and in line with the best global practices.

Explaining the scope of the guidelines, FSSAI says, “they pertain only to the recycling process and the operation of transforming post-consumer PET used for food applications into recycled PET as food contact material (FCM-rPET) resins suitable for making food contact materials.”

The norms cover the acceptance criteria for using FCM-rPET resins in food contact materials and apply only to recycling technology approved by FSSAI. The norms do not apply to the production of resins for non-food-grade consumer applications.

Four decontamination-based recycling methods have been approved – super-clean process; melt-in process; paste-in process; and chemical recycling process. Conventional recycling methods without proper decontamination have been prohibited.

Any one of the following recycling processes capable of producing recycled PET as food contact materials may be adopted. The recycling process will have at least one decontamination step capable of removing contaminants to a level of purity suitable for food contact.”

A conventional recycling process where PET flakes are washed, melted, extruded and pelletized without removing contaminants is not to be used for food grade recycling. “Such processes should not be used for manufacturing food contact materials as they do not have the decontamination process step,” FSSAI said.

Each recycling process must pass different tests categorized as ‘challenge,’ ‘extraction,’ and ‘migration’ to ensure all contaminants are removed. The tests have to be conducted by NABL or ILAC-accredited laboratories.

To ensure transparency and to educate consumers, FSSAI has made it mandatory to include a distinct logo to identify packaging made from food-grade recycled PET on labels. A declaration will specify the percentage of recycled PET used.

All FCM-rPET manufacturers, converters, beverage bottlers, food packers, and food business operators would have to maintain and provide relevant documentation about their downstream customers to the food regulator.

The documentation includes supply chain records on product traceability and quality assurance data on safety compliance at each level of the food chain. The documents also include a statement from the manufacturer declaring that the FCM-rPET conforms to all specifications. Manufacturers of r-PET resins will have to undergo an annual plant audit.

The FSSAI move assumes significance in the wake of the mandatory use of 30% recycled plastic for category 1 packaging, defined as rigid plastics, which includes PET bottles, primarily used by beverage manufacturers, from 1 April 2025.

Beverage and FMCG players feel the targets are impractical because of recycling infrastructure limitations, material shortage, and potential cost increases, and are even mulling legal recourse. The government is unlikely to budge, now that FSSAI has released the guidelines.

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Naresh Khanna – 21 January 2025

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