A new report from the Food and Agriculture Organization of the United Nations (FAO) has shed light on the food safety concerns associated with recycled plastic food contact materials (FCMs) and sustainable food packaging materials, like biobased polymers. Although the global need to mitigate plastic waste is widely accepted, the food safety implications of using recycled and renewable materials for food contact applications must be considered.

Addressing Food Safety Risks of Recycled Plastics

According to the available literature, plastic FCMs containing recycled materials carry specific food safety hazards, specifically:

• The presence of unsafe chemicals: When plastic recycling streams are poorly controlled, plastics unsuitable for food contact applications and plastics that have been subjected to post-consumer misuse may be mixed with food contact plastics. Additionally, recycling may introduce non-intentionally added substances (NIAS)
• Chemical migration: Studies have shown that recycled plastics release harmful NIAS such as metals, brominated flame retardants, persistent organic pollutants (POPs), and phthalates at higher quantities compared to virgin plastics. Additionally, decomposition and reaction byproducts of intentionally added substances (IAS)—such as surfactants, coatings, lubricants, antioxidants, thermal stabilizers, and biocides—can also migrate from recycled FCMs.
• Microplastics: The risk of micro- and nanoplastics exposure from food is not yet fully understood. Although microplastic shedding is not unique to recycled plastics, it may be a possible outcome of physical plastic recycling practices.

To address the chemical migration of NIAS and IAS from recycled plastic materials, approved recycling processes rely on extensive cleaning of post‑consumer plastic waste and the use of chemical surrogates designed to demonstrate the effective removal of a spectrum of chemicals, including those associated with possible consumer misuse. For migrating substances with unresolved chemical structures, a threshold of toxicological concern (TTC) approach can be used to evaluate potential human health risks from exposure to low levels of chemicals when toxicity data are limited.

Alternative FCMs and Bioplastics

Bioplastics are polymers produced from renewable resources with potentially better decomposition and degradation properties compared to fossil fuel-based plastics; for example, this mushroom-based polymer developed by University of Maine researchers.

Although bioplastics may provide a solution to sustainability challenges, they do some with specific chemical risks. For example, the source of the feedstock and the inherent properties of the starting biological material affect the chemical safety of the resulting bioplastic.

Moreover, “smart” FCMs—which include intentionally added compounds with functional purposes, like extending shelf-life, improving food quality, or enabling real-time monitoring of food freshness and safety—may facilitate the migration of unique chemicals, the safety of which must be considered during product development and premarket approvals.

Codex Work to Develop Guidance on Recycled FCMs

Given the absence of globally harmonized standards to ensure the safety of recycled plastics used in food packaging, the Codex Alimentarius Commission is considering developing guidance.

The Codex Committee on Contaminants in Foods (CCCF) agreed to prepare a discussion paper for its 19^th Session (CCCF19), taking place in October 2026, on developing guidance related to food safety considerations for the use of recycled materials in food packaging. If the proposal is approved, the guidance will focus on food safety aspects associated with the use of recycled plastics, particularly the potential for food contamination, and on their safe use in food packaging.