Circularity paradox: Circular packaging ≠ Food safety?

For the food packaging sector, the transition to a circular economy is no longer a theoretical debate—it is an operational reality dictated by strict brand mandates and aggressive legislative targets. However, a recent report by the Food and Agriculture Organization of the United Nations (FAO), titled Food Safety Implications of Recycled Plastics and Alternative Food Contact Materials, injects a harsh dose of technical reality into this green transition.

The takeaway is clear: in our rush to satisfy circularity targets, we risk compromising chemical food safety. To safely scale recycled Food Contact Materials (FCMs) and bio-based alternatives, the industry must move past sustainability rhetoric and confront a complex matrix of chemical risks, data gaps, and regulatory frameworks.

The report “Food Safety Implications of Recycled Plastics and Alternative Food Contact Materials”, released by the Food and Agriculture Organization of the United Nations (FAO).

The FAO is a specialized agency that leads international efforts to defeat hunger and achieve food security.

What are the primary chemical risks associated with recycled FCMs?

The core risk stems from the inherent volatility of post-consumer waste streams. Unlike predictable, high-purity virgin polymers, recycled plastics introduce a complex chemical matrix with migration risks posed by contaminants associated with Intentionally Added Substances (IAS) and Non-Intentionally Added Substances (NIAS).

Even within regulatory-approved recycling loops, systemic vulnerabilities lead to major contamination. These include:

- Industrial stream mixing of food-grade and non-food-grade plastics due to poor control.

- Post-consumer misuse, such as consumers using food containers to store household chemicals.

- Process degradation, which introduces new NIAS during recycling.

Furthermore, the degradation products of IAS, such as surfactants, coatings, lubricants, antioxidants, and thermal stabilizers, can also be subjected to migration from recycled plastics.

Studies cited by the FAO show that recycled FCMs can release higher quantities of harmful heavy metals, brominated flame retardants, persistent organic pollutants (POPs), and phthalates compared to virgin materials.

The new FAO report discusses safety considerations for recycled FCMs. (Source: FAO)

How can packaging converters mitigate these chemical migration risks?

Recycled plastics producers can no longer assume feedstock uniformity. To manage this volatility, quality assurance must move upstream. Brands must implement stringent incoming material testing protocols to profile chemical batches before they hit the production floor.

One pragmatic engineering solution highlighted by the report is functional barrier design. By sandwiching recycled polymers behind a layer of high-purity virgin plastic or a specialized barrier coating, packaging converters can physically block the chemical migration.

However, this introduces an economic and philosophical dilemma: does adding virgin layers defeat the ultimate goal of 100% recycled packaging? 

What is your take on shifting to circular food pcakaging? (Source: FAO)

Are bio-based packaging materials a safer alternative to recycled plastics?

No, renewable materials are not a silver bullet. The FAO report rightly cautions that bio-based alternatives introduce unique, highly complex chemical risks tied directly to the biological source material itself.

Natural plant fibers containing cellulose, hemicellulose, and lignin have been widely used as raw materials in the production of FCMs. In a study on plant‑based FCMs collected on the Dutch market, a gas chromatography‑mass spectrometry screening revealed the presence of plant extractable plasticizers, antioxidants, hydrocarbons and various metals, including lead and mercury.

Biomaterials bring an entirely different class of contaminants associated with NIAS to the kitchen table:

- Agricultural residues like pesticides and herbicides.

- Natural biological hazards including persistent natural toxins and allergens.

How can the industry evaluate unknown packaging contaminants?

Specific chemical migration limits, based on structural properties linked to toxicity, can help assess migrating substances when hazard data are scarce.

However, toxicological information for some FCM substances, especially NIAS, can be limited or inconsistent. To bridge this data gap, the FAO champions the Threshold of Toxicological Concern (TTC) approach as a pragmatic risk-screening tool for chemicals that may migrate from both virgin and recycled plastics.

The TTC approach assumes that reasonable assurance of safety can be achieved without chemical-specific data if dietary exposure is sufficiently low, and it is already used by regulatory agencies, including the USFDA, in evaluating FCMs.

The FAO further urges more research to clarify hazard profiles and establish migration thresholds for NIAS and contaminants in recycled FCMs. Continued development of reference databases and analytical tools for identifying IAS and NIAS in migration studies is also needed to improve acceptance of recycled plastics.

It is important to continously conduct research on NIAS and contaminants in recycled FCMs. (Source: FAO)

Do mechanical recycling practices contribute to the microplastic crisis?

Yes. Micro- and nanoplastics (MNPs) are not exclusive to recycled plastics but are possible byproduct of mechanical recycling practices. The physical shredding and size-reduction phase, combined with prior environmental weathering, accelerate MNP formation.

Polymers such as PET, PS, PP, and PE are highly susceptible to mechanical abrasion and thermal stress. Recent studies suggest that they can directly release MNPs from packaging materials into food and beverages.

Furthermore, nanomaterials are incorporated into packaging polymers to enhance key performance characteristics, such as strength, durability, flexibility, barrier properties, and overall service life. As IAS, these materials should undergo a premarket safety assessment before use.

Some evidence suggests that MNPs are entering the food supply, primarily through the environment. (Source: USFDA)

The Verdict: We need harmonization, not Isolation

The circular economy cannot succeed in a regulatory vacuum. To prevent regional market fragmentation, global standards are non-negotiable.

The FAO’s confirmation that the Codex Alimentarius Commission (CAC) is actively developing global food safety guidelines for recycled plastics is an important step toward realizing the full potential of recycled and alternative FCMs while safeguarding consumer health.

From an industry perspective, one key direction toward true progress is to standardize global testing metrics and build a global reference database of approved FCM chemicals organized by resin codes.

Download the full report “Food Safety Implications of Recycled Plastics and Alternative Food Contact Materials”: https://openknowledge.fao.org/items/61e5777f-b3fc-40df-b18b-5799fe37585b