On October 5, 2026, the Food Packaging Forum (FPF) submitted comments on a Codex Alimentarius discussion paper proposing the development of guidelines on the safe use of recycled plastics in food packaging. The discussion paper, prepared by the USA in collaboration with the EU, Japan, and Canada, will be discussed at the 19th meeting of the Codex Committee on Contaminants in Foods (CCCF) held in Cairo, Egypt on October 19–26, 2026. At the meeting, a decision will be made on whether work on developing the international guidelines will proceed.
In its submission, FPF welcomed the objective of addressing food safety concerns associated with recycled food contact materials (FCMs) and supporting safe circularity. However, FPF highlighted several scientific and implementation challenges that it thinks warrant further discussion before international guidelines are developed.
FPF’s main comments are focused on four topics. First, FPF notes that chemical migration is a well-documented phenomenon affecting many FCMs and is not unique to recycled plastics. While recycling can increase chemical complexity, similar chemical safety concerns also arise in primary plastics and other non-inert materials such as paper, aluminum, etc.
Second, FPF requests clarification regarding the rationale for developing guidance specifically for recycled plastics, noting that the original Codex proposal referred more broadly to recycled materials. FPF argues that similar chemical contamination concerns also apply to the recycling of other non-inert materials such as paper. However, no justification was provided for the omission of other materials from the proposed guidelines.
Third, FPF notes the insurmountable regulatory and analytical challenges in demonstrating the chemical safety of both primary and recycled plastic food contact materials, including in industrialized nations (FPF reported and here). This includes challenges such as dealing with non-intentionally added substances (NIAS), and the inability to fully characterize all chemicals that may be present in recycled plastics (FPF reported).
Finally, FPF notes that the discussion paper does not explicitly define “food safety,” despite safety being the central objective of the proposed guidance. FPF’s submission therefore calls for greater clarity on which concrete health outcomes and hazards are intended to fall within the scope of the guidelines.
FPF’s submission concludes that further scientific discussion is needed before high-level global guidance on the safe use of recycled plastics, or other recycled non-inert FCMs, can be developed.
In addition to these overarching comments, FPF’s submission contains detailed paragraph-by-paragraph comments on the discussion paper and its appendices.
Comments on the discussion paper were also submitted by other stakeholders including Codex member countries from every continent as well as industry associations, and can be read online.
FPF submitted its comments through the European Consumer Organisation (BEUC), an accredited Codex observer organization. The comments reflect FPF’s views and do not represent BEUC’s position.
References
Food Packaging Forum (October 5, 2026). “Comments on the Codex Alimentarius discussion paper on the development of guidelines on the safe use of recycled plastics in food packaging.” (pdf)
Codex Alimentarius Commission (August 2026). “Development of guidelines on the safe use of recycled plastics in food packaging.” (pdf)
