Introduction:
On May 23, 2025, the Food Safety and Standards Authority of India (FSSAI) issued detailed guidelines for the use of recycled Polyethylene Terephthalate (r-PET) as food contact material (FCM-rPET).[1] These guidelines are designed to enable the safe incorporation of recycled PET in food and beverage packaging, in line with the Ministry of Environment, Forest and Climate Change’s directive mandating that 30% of rigid plastic packaging, such as PET bottles, consist of recycled content by the financial year 2025–26.
Scope and Applicability:
FCM-rPET is defined as food-grade recycled PET that has undergone a validated decontamination process to achieve the level of purity necessary for direct contact with food. To ensure safety, such recycled materials must conform to Indian Standards including IS: 12252, IS: 9845, and IS: 9833, and testing must be conducted in NABL or ILAC-accredited laboratories. These guidelines are strictly limited to post-consumer food-grade PET used in the manufacture of food contact materials, and are applicable only when the recycling technology employed is approved by FSSAI. Applications involving non-food grade resin are explicitly excluded.
Approved recycling processes:
The guidelines recognise only those recycling technologies that include at least one decontamination step. These approved methods are super-clean recycling, melt-in recycling, paste-in recycling, and chemical recycling. In contrast, conventional mechanical recycling processes that do not incorporate any decontamination stage are not permitted for the production of food contact materials.
Testing and Validation:
To validate the decontamination efficacy of the recycling processes, three types of tests are mandated. A challenge test must demonstrate that residual contaminants in r-PET are below 220 µg/kg. A migration test must confirm that migration of substances into food or food simulants remains under 10 µg/kg. An extraction test is also required to quantitatively assess the substances present in FCM-rPET.
Marking and Labelling:
In terms of labelling, packaging made with FCM-rPET must display a designated logo that indicates the percentage of recycled content (e.g., “X% r-FCM-PET”). Additionally, it must include a clear declaration stating, “The packaging material is made with recycled PET.” The determination of recycled content must adhere to the methodology outlined in IS: 14534:2023.
Documentation:
Compliance with the guidelines requires manufacturers and downstream stakeholders such as converters, beverage bottlers, food packers, and food business operators (FBOs) to maintain specific documentation. This includes a declaration of compliance with applicable standards, regulatory approvals such as No Objection Certificates (NOC) or No Objection Letters (NOL), and complete quality assurance and traceability records across the supply chain.
Authorization:
Manufacturers seeking to produce FCM-rPET must obtain authorization from FSSAI by submitting Form I, which includes detailed technical, safety, and compliance information. Upon review, FSSAI may authorize or reject the application. Approved manufacturers will be listed on FSSAI’s website and will be subject to annual audits to ensure ongoing compliance with the established guidelines.
Conclusion:
The guidelines have been published at a time when the F&B industry has in the past raised concerns about the limited supply of r-PET material to meet the demands of beverage companies. By establishing clear regulatory criteria for the production, testing, labelling, and use of r-PET in food applications, FSSAI aims to not only ensure consumer safety but also encourage investment in compliant recycling infrastructure. These guidelines are expected to streamline approvals for recycling facilities, improve supply chain confidence, and accelerate the industry’s transition toward circular and sustainable packaging solutions in line with national environmental mandates.
[1] Ministry of Health and Family Welfare, FSSAI Notification No. SSDIVI-PF0SP20(16)/1/2025-Standard-FSSAI, New Delhi, the 23rd May, 2025. https://www.fssai.gov.in/upload/notifications/2025/05/6834550d9ff1eGuidelines%20for%20acceptance%20of%20recycled%20Polyethylene%20terephthalate_PET_as%20Food%20Contact%20Material.pdf