INSIGHT: The potential of recycled packaging for food contact in Asia

SINGAPORE (ICIS)–Is Asia seeing the acceptance of recycled plastics into food contact materials (FCMs)?

With no previous country-specific regulation to explicitly allow or prohibit the use of recycled plastics in food applications in Asia (except Japan), recent updates by Korea, China and Thailand indicate that the region may soon see food packaging applications using recycled materials.

“The use of recycled materials in FCM is becoming a ‘very hot topic’ in China,” China’s National Center for Food Safety Risk Assessment (CFSA) Deputy Director, Zhu Lei, said last month at a Chemical Watch Key Regulatory Updates conference, The agency is now conducting an industry survey and initiating a risk assessment method for recycled FCM.

In May 2020, Korea’s Ministry of Food and Drug Safety revised its ‘Standards and Specifications for Food Utensils, Containers and Packaging’ legislation. The revision allowed the use of recycled polyethylene terephthalate (R-PET) and polyethylene naphthalate (R-PEN) in food contact materials. Only chemically recycled resins are allowed, however, and may only be used in parts that do not come into direct contact with food, eg in multi-layer structures.

Thailand’s Food and Drug Administration is considering revising the Ministry of Health Notification No. 295 (2005) on plastic food containers to potentially permit the use of R-PET and recycled high density polyethylene (HDPE) for food contact.

Although Malaysia does not have a regulation on recycled plastics for packaging, some companies are incorporating recycled content as long as food regulation 27 is complied with.

These are major announcements that will drive the region’s circularity of plastics, further supporting the achievement of both country and brand’s sustainability targets. However, there are challenges the industry needs to address to ensure these FCMs are in fact ‘food grade’.

Food grade plastic is best defined as plastic that is safe to use, or does not cause harm to human health, in food contact applications.

The term refers to any plastic suitable for contact with consumable food or drink products, generally recognised by international certifications such as the European Food Safety Authority (EFSA) and Food and Drug Administration (FDA). However, the definition of food grade post-consumer plastics has yet to be defined in Asia.

Unlike EFSA (a body that that evaluates the safety of substances used in food contact materials in the EU), and FDA approval in the US, Asia has no overarching regulating body or regionally agreed definition of what food grade plastics are.

The more commonly heard-of ‘definitions’ of food grade in Asia, as shared by ICIS contacts, include – the usage of well-known Starlinger or Erema mechanical recycling technology, solid state polycondensation (SSP) treatment or extrusion, and usage of food grade pellets for manufacturing of food contact products.

The closest Asia has to a food grade regulatory framework for recycled plastics in food packaging would be Japan’s guidelines.

These combine government regulations: based on the Food Sanitation Act of 1947 and positive list system for food packaging materials by the Ministry of Health, Labour and Welfare (MHLW); as well as voluntary standards to ensure the baseline for safety of food-contact materials, established by industry trade associations such as the Japan Hygienic Olefin and Styrene Plastics Association (JHOSPA).

Companies operating in Japan may apply to become a JHOSPA member to attain this certification, however, there are no major negative repercussions for non-members.

Fast-moving consumer goods (FMCG) companies’ source recycled polymers from suppliers with food grade certification, and several Asian recyclers have identified this as an opportunity to expand their food grade rPET capacity. Recyclers producing FDA certified food grade post-consumer resins outside of Japan include: Duy Tan Plastics Recycling Factory, Vietnam; EcoBlue and Indorama, Thailand; Futura Polymers, India; Visy, Australia; and Far Eastern New Century Corporation (FENC), Taiwan.

While the definition of ‘food grade’ does not impact recyclers who are already FDA or EFSA certified, it raises the question of consistency and quality of product from other recyclers who claim to supply food grade material in the region, of which there are many.

As many large beverage and FMCG companies take the stance to commit to at least 50% recycled content in their packaging by 2030, brands will continue to source for food grade certified recycled materials.

ICIS discussions with major players found a commitment and willingness to bear higher prices for food grade recycled polymers; confirming that demand for recycled packaging materials in Asia is set to grow.

With the current limited global supply of food grade recycled plastics and a rising demand for recycled content in packaging, the global challenge for brands to gain access to high-quality food grade recycled plastics is a wide gap to bridge.

While Asia is increasing its capacity for recycled food and beverage packaging, harmonised certifications and standards will accelerate the journey towards achieving sustainability targets for higher recycled content in bottles and food packaging.

INSIGHT by Jia Hui Tan

For a copy of the ICIS monthly Asia R-PET prototype price report, contact hazel.goh@icis.com