June 9, 2025
Companies across the packaging industry are working to incorporate more post-consumer recycled (PCR) content in response to the global demand for more environmentally responsible materials. However, the use of recycled polyethylene (rPE) in food-contact applications carries strict compliance requirements, particularly under the U.S. Food and Drug Administration’s (FDA) regulations.
Manufacturers and recyclers must overcome an array of complex standards to make sure that mechanically recycled plastics meet the same safety and performance criteria as virgin materials. Chain-of-custody protocols, material purity verification, and adherence to good manufacturing practices each play a significant role in determining whether plastic recycling can be used in food packaging.
While these challenges require coordinated efforts across the supply chain, they also present opportunities to establish more efficient plastic recycling systems, expand access to high-quality recycled content, and contribute to a more circular plastics economy.
The demand for recycled plastics in food packaging is accelerating at an unprecedented rate, driven by both regulatory requirements and consumer expectations for more sustainable products.
The global recycled plastics market is projected to see substantial growth, rising from $55 billion in 2024 to $107 billion by 2032, according to Fortune Business Insights. Food brands and retailers are actively integrating PCR content into their packaging to meet ambitious sustainability goals and align with evolving environmental policies.
Extended producer responsibility (EPR) programs and government-imposed recycled content mandates are further shaping industry decisions, compelling companies to adopt materials that reduce reliance on virgin plastic. As more organizations pledge to increase the use of PCR plastic, recyclers and suppliers must scale operations to meet demand while maintaining compliance with stringent safety and quality standards.
The expansion of food-contact rPE depends on developing systems that can effectively manage contamination risks and uphold regulatory requirements throughout the supply chain.
In the U.S., the FDA imposes strict regulations on food-contact polyethylene, requiring that all materials meet the same safety and purity standards as virgin plastics.
Standard mechanical plastic recycling, while effective at removing surface contaminants, does not eliminate chemical additives such as antioxidants, colorants, and stabilizers, meaning that plastics with unapproved additives cannot be repurposed for food-contact applications.
The complexity of these regulations extends beyond material composition to include chain-of-custody requirements, which mandate thorough documentation of each stage in the plastic recycling process.
Recyclers and suppliers must verify the origins, composition, and prior uses of collected plastic films, adding operational challenges that require enhanced collaboration across the supply chain.
Companies looking to increase the use of rPE in food packaging must account for these regulatory hurdles while developing efficient processes that align with FDA standards and industry expectations.
For recycled rPE to be used in food-contact applications, a verified chain of custody must be established to demonstrate that materials meet stringent safety requirements.
Recyclers must track and document the journey of incoming plastic bales, confirming their composition, manufacturer, and previous use to prevent contamination from non-compliant additives or substances. Having this level of traceability is essential because the mechanical recycling process does not remove embedded chemical additives. As such, controlling inputs from the very start of the process is imperative.
Collection protocols must balance efficiency with accuracy, simplifying the tracking process for manufacturers, retailers, and distribution centers while maintaining strict oversight on the type and origin of rPE packaging entering the recycling stream.
The implementation of standardized documentation and auditing procedures across the supply chain allows for smoother verification processes, reducing regulatory uncertainties and improving the overall reliability of food-contact recycled plastics. Strengthening coordination between suppliers and recyclers helps create a more transparent system, making it easier for companies to meet compliance standards.
The FDA reviews each recycling process individually to determine whether rPE can be safely used in food packaging.
The industry standard for obtaining approval is the Letter of Non Objection (LNO), which signals that the proposed recycling method and chain-of-custody validation align with food-contact safety requirements. While obtaining an LNO is technically voluntary, it serves as an important step in building confidence among food brands seeking to integrate recycled content into their packaging.
A complete LNO submission must include a detailed description of the recycling process, outlining the sources of recyclable materials and the procedures used to maintain purity and prevent contamination.
The application must also provide test results demonstrating the effectiveness of contaminant removal during processing, proving that any remaining substances do not pose a risk to food safety. Finally, recyclers must specify the proposed conditions of use for the final rPE product, making sure that it aligns with FDA regulations for food-contact applications.
Without an LNO, food companies may hesitate to incorporate mechanically recycled plastics into their packaging due to concerns about regulatory acceptance and supply chain consistency. As demand for food-contact rPE grows, recyclers must prioritize compliance and transparency to support industry-wide adoption of sustainable packaging solutions.
The production of high-quality food-contact rPE depends on the efficiency and precision of recycling operations. Advanced sorting and washing systems play a fundamental role in eliminating contaminants, preserving material integrity, and making sure that the final product meets FDA standards.
Optical sorting technologies allow recyclers to accurately separate usable polyethylene films from non-compatible materials, reducing the risk of contamination at the earliest stages of processing.
At the facility level, good manufacturing practices provide the framework for maintaining strict hygiene, quality control, and regulatory compliance. More in-depth good manufacturing practice programs include personnel training, pest control, process water management, and contamination prevention, all of which contribute to the reliability and safety of food-grade recycled materials.
Dedicated wash lines and silo storage systems prevent cross-contamination between food-contact and non-food-contact plastics, helping recyclers meet the rigorous standards required for reuse in packaging.
Once contaminants and unwanted residues are removed, the extrusion process enhances the purity and performance of rPE. The final stage involves post-processing techniques such as hot-air circulation treatments, which reduce any lingering odors or flavors, producing a consistent and reliable material suitable for high-performance packaging applications.
Strengthening the supply chain for food-contact rPE requires an integrated approach, bringing together recyclers, packaging manufacturers, and material suppliers to develop efficient collection and processing systems. These collaborations are essential for scaling operations and meeting increasing demand from food brands committed to sustainability goals.
Industry-wide acceptance of recycled plastics depends heavily on education and open communication. The various stakeholders across the value chain must recognize both the economic advantages and the environmental benefits of rPE in food packaging.
A shared commitment to sustainability requires the development of standardized collection methods and clear chain-of-custody protocols, allowing for greater traceability and confidence in recycled materials.
The future of food packaging relies on expanding the availability of high-quality, food-contact recycled plastics that meet evolving safety and sustainability standards. The Food, Drug, and Cosmetic Packaging Materials Committee (FDCPMC) within PLASTICS plays a key role in addressing these challenges, collaborating across industry and regulatory bodies to support safe, innovative packaging solutions.
For those looking to stay ahead in sustainable plastics development and the latest in plastic recycling, joining PLASTICS provides valuable insights, access to active recycling initiatives, and opportunities to help shape the future of packaging through groups like the FDCPMC.
PLASTICS and the Future Leaders in Plastics (FLiP) Committee are devoted to supporting and encouraging the next generation of plastics leaders who will play a crucial role in the innovation, technology and future of the plastics industry. FLiP’s mission is to provide young professionals under the age of 40 the exposure, education and resources they need to build lifelong careers in plastics. Want to join? Want to get your employees involved? Email: [email protected]
