The push to reduce plastic waste is reshaping the food packaging sector. Recycled plastics, biobased polymers and other alternative materials are increasingly being explored as part of more sustainable packaging strategies.
But sustainability cannot be considered in isolation. When a material is designed to come into contact with food, food contact surfaces or the food production environment, its suitability still needs to be assessed through a food safety lens.
A new report from the Food and Agriculture Organization of the United Nations has examined the potential food safety implications associated with recycled plastics and alternative food contact materials, including bioplastics and “smart” packaging materials. It highlights an important issue for the food industry: packaging may be more sustainable, but that does not automatically make it appropriate for food contact use.
Recycled plastics are not all the same
Recycled plastic can play an important role in reducing packaging waste, but its use in food contact materials presents specific challenges.
One of the key issues identified in the FAO report is the potential for recycled plastic streams to contain materials that were never intended for food contact use. Poorly controlled recycling systems may allow non-food-grade plastics, contaminated post-consumer materials or plastics that have been misused by consumers to enter the recycling stream.
This matters because recycled materials can contain a wider range of chemical substances than virgin plastics. These may include residues from previous use, contaminants introduced during collection and recycling, or substances formed through degradation and processing.
Recycled plastics may also contain non-intentionally added substances, commonly referred to as NIAS. These can include chemicals such as metals, brominated flame retardants, persistent organic pollutants and phthalates. Some of these substances may migrate from packaging into food, depending on the material, the food type, temperature, contact time and conditions of use.
Chemical migration remains a central food safety issue
For food businesses, the key concern is not simply whether a packaging material is recycled, renewable or innovative. The more important question is whether it is suitable and safe for its intended food contact application.
Chemical migration is a long-established consideration in food contact material safety. However, recycled and alternative materials can introduce additional complexity because the chemical profile may be less predictable.
Substances of concern may include:
- residues from previous packaging use
- contaminants from the recycling stream
- additives used in the original plastic
- decomposition products formed during processing
- processing aids, coatings, lubricants, stabilisers or other intentionally added substances
- non-intentionally added substances formed through reactions or degradation
This is why approved recycling processes for food-contact materials typically require stringent controls, including effective sorting, thorough cleaning, validation that contaminants can be removed to safe levels, and full traceability of recycled materials. Knowing the source of recycled materials is crucial in mitigating the risk of contaminated materials being used in food-contact packaging.
Bioplastics and alternative materials are not risk-free
Biobased and biodegradable materials are often seen as more environmentally responsible alternatives to conventional plastics. However, “natural”, “renewable” or “biobased” does not automatically mean safe for food contact use.
The source of the feedstock, the manufacturing process, the additives used and the properties of the finished material all need to be considered. Biological starting materials may introduce their own chemical safety considerations, and the final polymer still needs to perform safely under real food contact conditions.
The same applies to emerging “smart” food contact materials, which may include functional ingredients designed to extend shelf life, monitor freshness or interact with the food environment. These technologies may offer benefits, but they can also introduce new substances that require careful safety assessment before use.
“Natural”, “renewable” or “biobased” does not automatically mean safe for food contact use.
Why independent assessment matters
For food businesses, packaging and other food contact materials are not just procurement decisions. They are part of the broader food safety system.
Any material, equipment, consumable or service used in food manufacturing, handling, storage or preparation can affect food safety outcomes. This includes packaging, processing components, food contact surfaces, finishes, cleaning materials, utensils, storage items and other non-food products used in the food environment.
This is where independent assessment has an important role to play.
HACCP International’s certification program assesses non-food products and services used by the food industry, including equipment, materials, machinery, supplies and services. The certification process considers a product’s material safety, accuracy and appropriateness in a food application, providing third-party assessment by food safety experts.
For suppliers, certification can help demonstrate that a product has been independently assessed for its intended use in food handling or food production environments. For food businesses, it provides an additional level of confidence when selecting products that may influence food safety.
As sustainable packaging options become more widely available, food businesses should be asking practical questions before adopting new materials, including:
- Is the material suitable for direct or indirect food contact?
- Has it been assessed for the specific food type, temperature and duration of use?
- What controls are in place for recycled content or feedstock sourcing?
- Is there evidence to support claims around migration, safety and suitability?
- Are any additives, coatings or functional substances present?
- Has the material been independently assessed for use in food environments?
These questions are especially relevant for products marketed as recycled, renewable, biodegradable, compostable or smart. While these attributes may offer environmental or operational benefits, they do not remove the need for technical assessment.
For packaging and material suppliers, independent certification can help bridge the gap between sustainability claims and food safety assurance.
Codex considers global guidance
The FAO report also points to the current lack of globally harmonised standards for recycled materials used in food packaging. This is significant because regulatory requirements for recycled plastics and other recycled food contact materials can vary between jurisdictions.
In March 2024, Codex sought comments from Members and Observers on whether it would be useful to develop guidance on food safety considerations related to the use of recycled material in food packaging. The consultation asked about existing government and voluntary programmes, food safety and trade issues, and technologies used to support the safety of recycled materials in food packaging.
The Codex Executive Committee later noted that comments had been received from 52 Members, 11 Observers and one Member Organization for consideration.
If this work progresses, it could help provide greater consistency in how food safety risks are assessed and managed as the industry moves toward more circular packaging systems.
Sustainability and food safety must move together
The transition to more sustainable packaging is necessary. However, food safety cannot be assumed simply because a material is recycled, renewable or marketed as environmentally preferable.
For food businesses, the practical message is clear, packaging and food contact materials need to be assessed through both a sustainability lens and a food safety lens.
That means asking better questions of suppliers, reviewing documentation carefully and ensuring products are suitable for their intended use in food handling, processing or packaging environments.
For suppliers, it also means being ready to demonstrate that sustainable innovations are not only better for the environment, but also appropriate for use in the food industry.
The future of food packaging will need to address plastic waste without creating new or poorly understood food safety risks. The challenge is not choosing between sustainability and safety. It is ensuring both are built into the decision-making process from the start.
Want to demonstrate the food safety suitability of your packaging, materials, equipment or services?
HACCP International provides independent certification for non-food products and services used in food handling and production environments. Learn more about certification of food safe equipment, materials and services.