On June 26, 2026, the Food Packaging Forum (FPF) sent a letter to the Food and Agriculture Organization of the United Nations (FAO), raising concerns about FAO’s recent report on recycled plastic and alternative food contact materials (FCMs).
In its letter, FPF outlines six key concerns regarding the report:
- Framing and narrative: The report emphasizes recycled plastic FCMs as necessary to tackle food waste, while overlooking a substantial body of scientific evidence demonstrating adverse human health and environmental impacts of recycled plastics.
- Interpretation of scientific studies: Several cited studies appear to be incompletely or incorrectly interpreted, potentially leading to a misrepresentation of the underlying scientific literature.
- Use of the threshold of toxicological concern (TCC) approach: The report presents the TTC approach as appropriate for risk assessing chemicals with limited toxicity data. However, TTC was developed as a screening and prioritization tool, not for doing chemical risk assessments, and has important limitations. In particular, it does not apply to substances with unknown chemical structures, which are common among food contact chemicals.
- Regulatory coverage: The report focuses on regulatory approaches in North America, the European Union, and Japan, but provides limited consideration of frameworks in other regions. Notably, China does not approve the use of recycled PET in food contact applications due to safety concerns.
- Practical implementation challenges: The report gives insufficient attention to real-world challenges associated with recycled plastics, evidenced by the fact that major retailers are scaling back commitments on recycled content in packaging.
- Risk assessment approach: The report relies heavily on classical risk assessment paradigms and does not fully reflect evolving scientific understanding, including concerns related to endocrine-disrupting chemicals (EDCs), carcinogenic, mutagenic and reprotoxic substances (CMRs), and mixture toxicity.
FPF hopes that the FAO will consider these comments in revisions to the report and remains open to engaging constructively to support the communication of balanced, science-based information on FCMs to a global audience.
References
FAO (May 13, 2026). “Food safety implications of recycled plastics and alternative food contact materials.”
Food Packaging Forum (June 25, 2026). “Letter to FAO: Key concerns regarding FAO report on recycled plastic food contact materials.” (pdf)
