Food-Grade Recycled Plastic: EFSA, FDA and Safety

Food-grade recycled plastic is one of the most carefully regulated materials in the packaging world, and for good reason: the polymer that once held a forgotten chemical in someone’s garage might, after recycling, end up wrapped around a sandwich. The central question is not whether recycled plastic can look clean, but whether it can be proven safe at the molecular level. Over fifteen years of running quality control for food-contact recyclate, I have watched this field move from cautious experiment to mainstream practice. Today, recycled PET (rPET) bottles can be turned back into food-safe bottles routinely, while recycled HDPE and PP are still climbing the same regulatory ladder. This article explains what actually makes recycled plastic safe for food, how regulators in the EU and US verify that safety, and why rPET still dominates the food-grade conversation.

What “Food-Grade” Actually Means for Recycled Plastic

The phrase “food-grade” gets used loosely, but in a regulatory sense it has a precise meaning. A food-contact material must not transfer its constituents into food in quantities that could endanger human health, change the food’s composition in an unacceptable way, or alter its taste and smell. For virgin plastic, manufacturers achieve this by starting with controlled, well-characterised raw materials. For recycled plastic, the challenge is fundamentally different: you start with material whose history you do not fully control.

A post-consumer plastic bottle has lived a life. It may have been refilled with cleaning fluid, stored fuel, or sat next to pesticides in a shed. Recyclers cannot inspect every individual item, so the safety question becomes statistical and process-based rather than item-by-item. Food-grade recycled plastic, properly defined, is recyclate produced by a process that has been demonstrated, through testing and modelling, to reduce any plausible contamination to a level that poses no meaningful risk to the consumer. The emphasis is on the process, not just the final pellet.

This is why food-grade status is granted to recycling processes, not simply to bags of flakes. Two recyclers can buy identical bottle bales and produce material of very different safety profiles depending on how they sort, wash, and decontaminate. Understanding that distinction is the first step toward understanding everything that regulators require. If you want a refresher on how recyclate is produced in the first place, our overview of how recycling actually works sets the stage.

It also helps to be precise about what counts as recycled content here. Food-grade recyclate is overwhelmingly post-consumer material, meaning packaging that has already served a consumer and entered the waste stream, as opposed to post-industrial offcuts that never left the factory. Post-industrial scrap is comparatively clean and predictable, but it is not what most recycled-content targets are designed to reward, and it is not where the difficult safety questions live. The whole regulatory apparatus exists precisely because food-grade recycling aims at the harder, more valuable goal of returning genuine post-consumer waste to food contact rather than relying on tidy factory trim.

The Contamination Challenge: Why Recycled Plastic Is Different

The core safety problem with recycled plastic is contamination, and it comes from two directions. The first is misuse: consumers who fill a beverage bottle with something it was never meant to hold. The second is the recycling stream itself, where non-food packaging, adhesives, inks, labels, and the residue of previous contents all mingle together before sorting.

Plastics are not inert sponges; they can absorb and slowly release small molecules. A molecule that diffuses into the polymer wall during a bottle’s first life can later diffuse back out, a phenomenon known as migration. If that molecule happens to be toxic, you have a problem that washing alone will not solve, because surface cleaning does not reach contaminants that have penetrated the polymer matrix. This is the heart of why food-grade recycling is hard and why it requires more than a good wash line. The quality of upstream plastic sorting directly determines how much contamination the decontamination step has to remove.

Regulators handle this uncertainty with a conservative assumption. Rather than trying to catalogue every possible contaminant, EFSA assigns a reference contamination level for post-consumer PET, conservatively set at 3 milligrams per kilogram of PET for substances resulting from possible misuse. The recycling process must then be shown to bring contaminants down from that worst-case starting point to a safe residual. It is a clever way of turning an unknowable problem (what was in every bottle?) into a measurable one (how well does this process clean a deliberately contaminated bottle?).

There is an important nuance worth flagging for anyone new to the field. The migration risk is not the same for every shape of finished product, and it scales with the surface-to-volume relationship between the article and the food it holds. A thin film in prolonged contact with a fatty food behaves very differently from a rigid bottle holding water for a short time. This is why migration assessment always specifies contact conditions, and why food-grade approvals are tied to defined uses rather than granted as a blanket pass. A pellet that is perfectly safe for a cold beverage bottle is not automatically cleared for a hot-fill tray, and serious quality programmes never blur that line.

Super-Clean and Decontamination Processes

The technologies that make food-grade recyclate possible are collectively known as super-clean or decontamination processes. Ordinary recycling washes flakes, removes labels and contaminants, and re-melts the polymer into pellets. That is enough for non-food applications such as fibre, strapping, or detergent bottles. Food-grade recycling adds a decontamination stage specifically designed to drive volatile and migratable substances out of the polymer itself.

For PET, the dominant approach combines heat, vacuum, and residence time. The cleaned flakes or pellets are held at elevated temperature, often close to the polymer’s softening point, under reduced pressure for a defined period. Under these conditions, absorbed contaminants diffuse out of the polymer and are carried away by the vacuum, much as moisture leaves a heated, evacuated chamber. Some processes apply this to flakes, others to pellets, and several integrate it with solid-state polycondensation that simultaneously rebuilds the polymer’s molecular weight after the thermal stress of melting.

• Temperature: high enough to mobilise contaminants without degrading the polymer.
• Vacuum or inert gas stripping: physically removes the substances that diffuse out.
• Residence time: long enough for diffusion to reach the required cleaning efficiency.
• Input control: food-grade, separately collected post-consumer material as the starting point.

Commercially, these processes carry brand names familiar to anyone in the trade, and each individual installation must prove its own performance. The principle is shared, but the parameters (temperature, pressure, dwell time) are tuned per process and per polymer. This is the practical machinery behind the regulatory paperwork, and it sits squarely within the wider toolkit of mechanical versus chemical recycling. Decontaminated mechanical recycling is what currently underpins almost all food-grade rPET on the market.

Why rPET Dominates Food-Grade (and rHDPE and rPP Are Harder)

If you look at the food-grade recyclate market, rPET is everywhere and the others lag well behind. There are good chemical and logistical reasons for this, not merely historical accident. Our deep dive on PET recycling from bottle to rPET covers the loop in detail, but the food-grade angle deserves its own explanation.

First, PET is processed at high temperatures under vacuum during normal recycling, which happens to be exactly the condition that strips out contaminants. PET decontamination is therefore a natural extension of standard reprocessing rather than a bolt-on. Second, PET diffusion behaviour is well understood and relatively slow at room temperature, so migration models for PET are mature and trusted by regulators. Third, and crucially, PET has a clean closed loop: deposit and bottle-collection systems deliver large volumes of separately collected, predominantly food-contact PET bottles. The input is already mostly food-grade, which makes proving safety far easier.

HDPE and PP face steeper obstacles. HDPE readily absorbs odours and substances from its previous contents, and much post-consumer HDPE comes from non-food packaging such as detergent and personal-care bottles, so sourcing genuinely food-grade input is difficult. Polypropylene suffers from a sorting problem: separating food-contact PP from the enormous pool of non-food PP is not economically feasible by hand, and automated systems to do it reliably are still being scaled. Both polymers are processed at lower temperatures than PET, so decontamination requires dedicated, more aggressive steps rather than riding along with normal reprocessing.

None of this means rHDPE and rPP are stuck. Food-grade rHDPE and rPP processes have received favourable assessments and FDA acknowledgements, and the trajectory mirrors what rPET went through years ago: early reluctance, extensive trialling, then mainstream acceptance. For now, expect higher price premiums and tighter supply for food-grade polyolefins than for rPET. The differences between grades are explored further in our piece on HDPE recycling grades and the rHDPE market.

EU Regulation 2022/1616 and EFSA Challenge Testing

The European framework for recycled food-contact plastic is Commission Regulation (EU) 2022/1616, which entered into force on 10 October 2022, replacing the earlier 2008 rules. It sets out which recycling technologies are considered suitable, how individual processes are authorised, and the central role of the European Food Safety Authority (EFSA) in risk assessment.

Under the regulation, a recycling technology must first be recognised as suitable, and then individual recycling processes using that technology require their own authorisation. At present, the regulation centres on two suitable technologies: mechanical recycling of food-grade, separately collected post-consumer PET, and closed-loop recycling, where food-grade plastic is cleaned and reprocessed for the same purpose it originally served. Novel technologies can be added once EFSA evaluates whether they are suitable for the kind of plastic input they target.

EFSA’s job, set out in Article 18 of the regulation, is to assess the migration risks from recycled food-contact materials, evaluate their microbiological safety, and deliver a scientific opinion on each recycling process. The methodology rests on the challenge test. A recycler deliberately contaminates virgin or clean polymer with a set of surrogate substances, runs that material through its full process, and measures how much of each surrogate remains. The decontamination efficiency obtained from this test is then applied to the conservative reference contamination level.

The resulting residual concentration in the recycled PET is compared against a modelled migration figure calculated with conservative migration models. The benchmark is strict: the related migration must not give rise to a dietary exposure exceeding 0.0025 micrograms per kilogram of body weight per day, the human exposure threshold for chemicals carrying structural alerts for genotoxicity. In plain terms, the process must clean the plastic so thoroughly that even a worst-case contaminant could not migrate into food at a level of toxicological concern. EFSA has published detailed scientific guidance describing exactly how these post-consumer mechanical PET recycling applications must be prepared and evaluated, and it issues individual opinions on named processes.

The US FDA Letter of No Objection (LNO)

The United States takes a structurally similar but procedurally different route. The FDA does not “approve” recycling processes in a formal pre-market sense. Instead, a recycler submits its process for voluntary review, and if the agency is satisfied, it issues a Letter of No Objection (LNO), sometimes called a No Objection Letter. The LNO states that the FDA has no objection to the use of recyclate from that process in specified food-contact applications. It is a strong market signal, even though it is technically a non-objection rather than an authorisation.

The scientific basis is again the challenge test, here described as surrogate contaminant testing. The FDA recommends that recyclers contaminate polymer with surrogates spanning at least four categories: volatile polar, volatile non-polar, non-volatile polar, and non-volatile non-polar. These categories are chosen to represent the broad chemical space of substances a consumer might plausibly introduce. The contaminated polymer is run through the recycling process, and the agency evaluates whether the process reduces the surrogates to acceptable residual levels and whether any remaining migration falls within safe dietary concentration limits.

The two systems converge on the same logic even though their paperwork differs. Both deliberately challenge the process with representative contaminants, both measure decontamination efficiency, and both translate that efficiency into a worst-case migration estimate compared against a health-based limit. A recycler selling into both markets typically designs a single challenge-test programme that satisfies both EFSA and FDA expectations, which is exactly how we structure validation work at Plastic Trader for material destined for food-contact buyers.

Migration Testing and Traceability in Practice

Process authorisation is the headline, but day-to-day food-grade quality control rests on two ongoing pillars: migration testing and traceability. Migration testing measures what actually transfers from a finished article into food or food simulants under defined time and temperature conditions. Overall migration limits cap the total mass of substances that can move into food, while specific migration limits restrict individual substances of concern. For recycled material, these tests confirm in the real article what the challenge test predicted at the process level.

Traceability is the less glamorous but equally vital half. A food-grade claim is only as good as the documented chain behind it: where the input came from, that it was separately collected food-grade material, which authorised process treated it, and what proportion of recyclate sits in the final article. Both EU and US frameworks expect this documentation to be available and consistent. In my experience, the most common reason a shipment fails a customer audit is not a chemistry failure but a paperwork gap: a missing process reference, an unverifiable input source, or an inconsistent declaration of compliance.

• Declaration of compliance: the document linking the material to an authorised process and stated use conditions.
• Input verification: evidence that feedstock was food-grade and appropriately collected.
• Batch records: traceable lots tying finished articles back to specific production runs.
• Periodic migration testing: ongoing confirmation rather than a one-time check.

This discipline is what allows food-grade recyclate to participate credibly in a genuine circular economy rather than being quietly downcycled. It also dispels a stubborn myth that recycled plastic is inherently dirtier or less safe than virgin; with an authorised process and proper traceability, food-grade rPET meets the same migration limits as virgin PET. For more on where that myth comes from, see our roundup of recycling myths. Suppliers operating across the EU market, such as European Recycling, build their whole offer around exactly this documented assurance.

Where the Rules Are Heading

Food-grade recycling does not exist in isolation; it is being pulled forward by broader packaging policy. Recycled-content targets are pushing brands to source more food-grade recyclate, which in turn pressures the system to qualify more processes and more polymers. The EU’s packaging rules increasingly tie market access to recyclability and recycled content, a direction explored in our explainer on the PPWR packaging regulation.

Expect three trends to continue. First, more individual PET process authorisations under Regulation 2022/1616 as EFSA works through its application queue. Second, gradual expansion of food-grade polyolefin recycling as sorting technology and decontamination for HDPE and PP mature toward the position rPET reached years ago. Third, tighter scrutiny of input quality, because the cleanest decontamination process in the world cannot compensate indefinitely for a poorly collected, contaminated feedstock. The lesson I keep returning to after fifteen years in the field is simple: food-grade safety is built at the start of the chain, in collection and sorting, just as much as it is verified at the end.

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