The Ministry of Health and Family Welfare, through the Food Safety and Standards Authority of India (FSSAI), issued the Guidelines for Acceptance of Recycled Polyethylene Terephthalate (PET) as Food Contact Material (FCM-rPET). These guidelines, published on 23rd May, 2025, provide regulatory provisions for the safe use of recycled PET in food packaging applications.

Key Highlights:

1. Application & Scope

• Applies entirely to the recycling/operation process of converting post-consumer PET used for food applications into recycled PET as Food Contact Material (FCM-rPET) resins suitable for manufacturing Food Contact Materials.
• Covers the acceptance criteria for using FCM-rPET resin in Food Contact Materials.
• Applicable only to recycling technologies approved by the Food Safety and Standards Authority of India (FSSAI).
• Not applicable to the production of recycled PET intended for non-food grade consumer applications.

2. Definitions

• Food Authority– means the Food Safety and Standards Authority of India (FSSAI) established under Section 4 of the Food Safety and Standards Act, 2006.
• Manufacturer– means the operator of an approved recycling process and/or a manufacturer of FCM-rPET as per FSSAI-approved technology.
• Materials
• Virgin PET (vPET): PET derived via poly-condensation of ethylene glycol and terephthalic acid.
• Post-Consumer Food Grade PET: vPET and FCM-rPET packaging collected from households or institutions, including returns from the distribution chain.
• PET Resin: Aggregated fragments from grinding and washing of post-consumer or pre-consumer industrial PET, intended for food application.
• Recycled PET (FCM-rPET): Post-consumer PET resin that has undergone validated decontamination to meet purity levels suitable for direct food contact.

3. Approved Recycling Processes

Only recycling technologies that include at least one decontamination step to reduce contaminants to safe levels for food contact are permitted.
Acceptable recycling processes include:

1. Super-Clean Recycling Process: A conventional recycling process with an integrated decontamination step involving surface treatment, high heat, and/or high vacuum in a controlled environment.
2. Melt-in Recycling Process: Involves vPET production incorporating decontaminated PET flakes in molten form using high heat and vacuum treatment.
3. Paste-in Recycling Process: A virgin PET (vPET) production process incorporating PET flakes in paste form through partial glycolysis, coupled with contaminant removal systems such as chemical distillation and vacuum degassing.
4. Chemical Recycling Process: Involves pyrolysis or full depolymerization of PET flakes into purified monomers like ethylene glycol and terephthalic acid or dimethyl terephthalate, in accordance with ISO 15270. These purified monomers may be used to produce PET of virgin quality. Manufacturers using chemical recycling must submit application and relevant dossier as per Form I to FSSAI.

Note: Conventional Recycling Processes that involves washing, melting, extruding, and pelletizing PET flakes without a decontamination step are not permitted for producing food contact materials.

5. Testing Requirements

The following tests are mandated to validate the safety of FCM-rPET:

• Challenge Test: Validates the decontamination efficacy by spiking PET with chemicals of varying molecular weights and polarities and analyzing residual concentrations post-recycling. Must be repeated upon any process or input change.
• Extraction Test: a quantitative analysis of substances present in recycled Polyethylene terephthalate (PET) as Food Contact Material (FCM-rPET).
• Migration Test: Analyses substances migrating from vPET or FCM-rPET resin containers into food; results must comply with specific and overall migration limits as per applicable plastic contact material standards.

All tests must be conducted in NABL/ILAC-accredited laboratories, following standards IS: 12252, IS 9845, IS 9833, and their latest amendments.

4.  Process Requirements

1. Process Input
• Input materials must meet minimum quality standards for FCM-rPET resin and be controlled based on process validation criteria as identified by performance of the challenge test.
2. Process Validation
• Decontamination efficiency must meet one of the following:
• Resin-based criterion: Contaminants ≤ 220 µg/kg in resin (via Challenge Test).
• Food-based criterion: Contaminants ≤ 10 µg/kg in food or simulant (via Migration Test).
• FCM-rPET must conform to PET specifications as per IS: 12252.
3. Process Output
• To ensure consistent FCM-rPET quality, the output must be regularly monitored through chemical analysis, using either extraction tests on the resin or migration tests on finished food contact products.
• Sensory testing of FCM-rPET shall be conducted in accordance with ISO 13302 or equivalent.
4.  Process Operation & Management
• Recycling process must follow Good Manufacturing Practices with a defined quality assurance program. Critical quality parameters, supply chain records, and safety data must be maintained to validate decontamination efficiency and ensure full product traceability.

5. Marking & Labelling Requirements

1. Label Specifications for FCM-rPET Products:  The label must display the percentage of recycled resin used (X%), along with the abbreviations and terms: r (recycled), FCM (Food Contact Material), and PET (Polyethylene Terephthalate).
2. Label statement: “The packaging material is made with recycled PET.”

6. Documentation Requirements

FCM-rPET manufacturers, converters, beverage bottlers, food packers, and FBOs shall maintain and provide the following documentation to downstream entities and the Food Authority upon request:

(a) Declaration of Compliance: Manufacturer’s written confirmation that FCM-rPET complies with IS: 12252.

(b) Regulatory Opinion: No Objection Certificate (NOC) or No Objection Letter (NOL) issued by a competent authority validating the recycling process for post-consumer food-grade PET.

(c) Supply Chain Records: on product traceability and quality assurance demonstrating safety compliance at all supply chain levels.

7. Authorization Process

Manufacturers shall apply to the Food Authority for recycling process approval by submitting the required details as per Form-I. Recycling plants producing r-PET resins will undergo annual audits.

The Food Authority shall:

a) Authorize or reject applications based on assessment (as per Form-II),

b) Maintain a registry of all authorized manufacturers and processes on the FSSAI website.

c) Request additional information from recognized manufacturers as needed.