On September 16, 2026, the Food Packaging Forum (FPF) submitted comments to three European Commission calls for evidence related to the Packaging and Packaging Waste Regulation (PPWR) (FPF reported). Through these consultations, the Commission specifically seeks to 1) establish sustainability criteria for plastic recycling technologies, 2) develop conditions for importing recycled materials into the EU for use in packaging, and 3) harmonize rules for calculating and verifying recycled content in plastic packaging.
Across the three submissions, FPF emphasized that implementation of the PPWR should explicitly account for chemical safety alongside circularity and environmental objectives. The comments highlighted the need for transparent and verifiable information on material flows and chemical composition, particularly where recycled materials are intended for sensitive applications such as food packaging.
Chemical safety as a sustainability criterion
In its comment on sustainability criteria for plastic recycling technologies, FPF highlighted evidence that recycled plastics can contain substances of very high concern (SVHCs), other hazardous chemicals, and chemicals with unknown toxicological profiles. These substances may originate from the original material formulation, previous uses, or contamination during recycling.
FPF therefore stated that chemical safety should be explicitly included among the criteria used to assess the sustainability of plastic recycling technologies. It also called for improved traceability and transparency of chemicals throughout the packaging value chain, including information on intentionally added substances such as additives and processing aids. The comment further noted the need for guidance to identify and manage potentially problematic non-intentionally added substances (NIAS) in recycled plastics.
Beyond chemical composition, FPF noted that sustainability assessments would benefit from considering unintended releases and other impacts associated with recycling processes, including microplastic generation, hazardous chemical use and waste streams, and overall resource and energy requirements. It referred to recent reports by the Swiss government and the European Commission’s Joint Research Centre that raise questions about the environmental benefits, technical feasibility, and cost effectiveness of chemical recycling (FPF reported and here).
FPF’s FCCmigex and FCCprio databases, which compile publicly available evidence on chemicals detected in food contact materials and associated hazard information, were cited as potential resources to support the development of chemical safety criteria.
Traceability and verification for imported recycled materials
In its comment on the conditions for importing recycled materials from outside the EU for use in packaging, FPF noted that such imports present challenges concerning traceability, transparency, chemical safety, and verification of claims throughout the supply chain. It highlighted the importance of requirements that ensure imported recycled materials meet standards equivalent to those applied within the EU, including for food packaging applications.
FPF stated that imported recycled plastics and paper should be properly evaluated for chemical safety before being used in food packaging. FPF also reiterated that, at a minimum, information on intentionally added substances, including additives and processing aids, could be made available to stakeholders throughout the value chain, including importers, regulators, and consumers. The submission further highlighted the need for guidance on identifying and managing NIAS that may be present in recycled materials.
The comment further noted the need for robust, transparent, and verifiable requirements on chemical composition and safety, including approaches that assess the mixture toxicity of the overall migrate from food contact materials. FPF suggested that dedicated research and development could support improved testing methods for establishing chemical safety in line with Article 3 of the food contact regulation (Regulation (EC) No 1935/2004). FPF also offered to share relevant evidence and expertise from FCCmigex and FCCprio with the Commission.
Transparent and verifiable recycled-content claims
In its third submission, FPF commented on the calculation and verification of recycled content in plastic packaging. Drawing on its Brand and Retailer Initiatives Database (BRID), FPF noted that in recent years more than 190 voluntary commitments made by companies concerning recyclability or recycled content had later been cancelled or scaled back. It therefore highlighted the need for approaches that make recycled-content claims transparent, scientifically robust, and verifiable throughout the supply chain.
FPF raised specific concerns about methodologies that weaken the relationship between recycled inputs and final products. It noted that a mass balance approach may attribute recycled content to an individual packaging unit even when that attribution does not correspond to the unit’s physical composition (FPF reported). According to the comment, this disconnect could mislead consumers and complicate assessments by regulators and other stakeholders of the chemical safety and sustainability of materials placed on the market.
FPF concluded that methodologies used to demonstrate recycled content should be transparent, auditable, and reflect physical material flows as closely as possible. This would also support independent product testing, biomonitoring, and environmental monitoring as complementary sources of evidence for regulatory oversight.
References
Food Packaging Forum (September 16, 2026). “Comments on the European Commission’s call for evidence related to ‘Packaging and packaging waste – sustainability criteria for plastic recycling technologies’.” European Commission. (pdf)
Food Packaging Forum (September 16, 2026). “Comments on the European Commission’s call for evidence related to ‘Packaging and packaging waste – conditions for importing recycled materials into the EU for use in packaging’.” European Commission. (pdf)
Food Packaging Forum (September 16, 2026). “Comments on the European Commission’s call for evidence related to ‘Plastic packaging – harmonisation of rules for calculating and verifying recycled content in plastic packaging’.” European Commission. (pdf)
