FAO Warns Recycled Food Contact Plastics Need Stronger Safeguards: What Food Brands Should Ask Suppliers Now

The UN Food and Agriculture Organization published a report on May 13, 2026 with an uncomfortable message for food brands chasing recycled content targets: the recycled plastics, bio-based materials, and “alternative” food contact materials now flooding the market may not be as safe as the sustainability story suggests.

The report — Food safety implications of recycled plastics and alternative food contact materials — landed three weeks before the May 31 EPR reporting deadline in California, Colorado, and Oregon. The timing is awkward. Brands are scrambling to hit recycled content thresholds at the same moment FAO is telling regulators those thresholds may be outrunning the safety science.

What the Report Actually Says

FAO’s analysis covers three material categories: recycled plastics (mechanical and chemical recycling), bio-based plastics (PLA, PHA, starch blends, cassava and sugarcane derivatives), and protein-based materials (whey, casein, gelatin films). For each, the report flags chemical migration risks that current global food safety frameworks don’t fully address.

The headline concern is what regulators call NIAS — non-intentionally added substances. These are chemicals that end up in a food contact material but weren’t deliberately put there: degradation products from processing, residues from prior consumer use, contamination from improper sorting, leftover ink, adhesive, or label residue. NIAS are notoriously hard to identify because there isn’t a fixed list to test against — every recycled batch is potentially different.

Corinna Hawkes, FAO Director of Food Systems and Food Safety, framed the issue directly: food safety has to be “a central consideration” in the sustainability transition, not an afterthought. The report explicitly warns against assuming that recycled or bio-based equals safe.

Why rPET Is the Main Concern

The one recycled polymer FAO named explicitly is rPET — recycled polyethylene terephthalate. That’s the workhorse of beverage bottles, salad clamshells, ready-meal trays, and water bottles, and it’s the recycled stream most food brands are mandated to use to meet upcoming recycled content targets (California’s SB 54 escalates plastic packaging recycled content requirements through 2028 and beyond; the EU PPWR sets a 25% recycled content minimum for PET beverage bottles by 2030).

The chemistry problem with rPET isn’t theoretical. Mechanical recycling melts and re-pelletizes PET that was previously in consumer use — bottles that may have held household cleaners, automotive fluids, or anything else a consumer chose to refill. Even at industrial recyclers with strict sortation, antimony residues, acetaldehyde, decomposition oligomers, and the occasional unidentifiable contaminant slip through. FDA’s “Letter of No Objection” process for rPET recyclers covers the recycling technology, not every input batch.

Chemical recycling (depolymerization back to monomer, then re-polymerization) produces resin that is chemically equivalent to virgin PET — but the process is more energy-intensive, more expensive, and only a few facilities at commercial scale exist globally. Most rPET on the market today is mechanically recycled.

Bio-Based Isn’t a Clean Substitute

The report’s second uncomfortable finding is that brands swapping to bio-based materials may be trading one risk for another. Plastics derived from corn, sugarcane, and cassava can carry over pesticide residues from agriculture, natural toxins (mycotoxins from contaminated crops), and allergens — particularly relevant for protein-based films like whey or gluten-derived coatings, which can transfer trace allergens into food.

Nanomaterials get a specific call-out. FAO notes the industry is adding nanoclays, silver nanoparticles, and nano-coatings to improve barrier performance and enable active packaging, but the toxicology data for nano-scale food contact additives is “underdeveloped.” Validated test methods for detecting micro- and nano-plastics in actual food don’t yet exist at the regulatory level, so even when there’s reason to look, regulators can’t measure.

This puts brands in an awkward position. The EU is pushing harder on recycled content. California is pushing on recycled content. Consumers expect “biodegradable.” But the underlying food safety infrastructure hasn’t been built to validate the new materials at the same speed.

What This Means for Codex and Future Rules

The report will feed into the Codex Alimentarius Commission, the joint FAO/WHO body that sets international food standards. Codex food contact material guidance is what national regulators (FDA, EFSA, China’s GB standards, FSANZ in Australia/NZ) reach for when writing their own rules. If Codex tightens guidance on recycled and alternative FCMs over the next 18 to 24 months, expect tighter migration testing requirements, more NIAS documentation, and possibly approved-supplier lists for recycled food contact polymers.

For brands selling internationally, this matters a lot. A rPET bottle that’s compliant in one country today may be flagged in another after a Codex update — and brand owners (not just resin suppliers) carry final responsibility for the food contact compliance of their packaging. (For a refresher on FDA’s framework specifically, see our FDA Food Contact Compliance Checklist.)

Five Questions to Ask Your Packaging Supplier This Month

The FAO report isn’t actionable on its own — it’s a directional warning. But it gives food brands clear ground to ask suppliers harder questions. If you use any recycled-content or bio-based food contact packaging, get the following on file:

1. Migration testing reports for the specific batch type, not just the polymer family. A generic “PET-compliant” letter isn’t enough. Ask for overall migration and specific migration data tested per EU Regulation 10/2011 or FDA 21 CFR 177, on the actual recycled grade and packaging format you’re buying.

2. NIAS screening reports. Reputable European converters increasingly run targeted NIAS screens using GC-MS or LC-MS. If your supplier can’t provide a recent NIAS report for the specific recycled grade in your packaging, that’s a gap.

3. Recycling input traceability. Where does the recycled resin come from? Bottle-to-bottle closed loops (deposit return system PET, for example) are much lower risk than open mechanical recycling streams. Ask for the certification chain — EuCertPlast, RecyClass, APR Letter of No Objection.

4. Updated FDA Letter of No Objection (LNO) for the recycler. For rPET used in US food contact applications, the recycling process needs an FDA LNO. These are published; you should be able to verify the recycler’s specific letter rather than taking it on trust.

5. For bio-based materials, allergen and pesticide screening. If your supplier uses corn, sugarcane, cassava, or dairy-derived films, request residue testing reports and an allergen risk assessment — particularly if you sell into allergen-sensitive categories (infant formula, gluten-free, organic).

These aren’t unreasonable asks. The converters who’ve already invested in food safety documentation will have these ready. The ones who can’t produce them in 30 days are not the suppliers you want when Codex or your national regulator tightens the rules. (For perspective on how this overlaps with other 2026 chemical compliance work, see our coverage of the EU BPA ban.)

The Bigger Picture

The FAO report doesn’t say recycled plastics shouldn’t be used in food packaging. It says the safety frameworks need to catch up to the volume. For procurement managers and brand owners, the practical move is to treat “recycled content” the same way you’d treat any other technical packaging spec — verify, document, audit, and don’t accept a marketing claim as a compliance answer. The regulators will eventually require this anyway; brands that build the documentation now will move faster when the rules formalize.

If you need help auditing your current food contact packaging documentation, comparing supplier compliance packages, or sourcing rPET and bio-based materials with verified food safety reports, get in touch at gqthpack.com. We work with food brands across NA, EU, and APAC on packaging that holds up to both regulatory and brand-level scrutiny.