The Ministry of Health and Family Welfare, through the Food Safety and Standards Authority of India (FSSAI), has issued guidelines for the acceptance of recycled Polyethylene terephthalate (PET) as Food Contact Material (FCM-rPET). These guidelines, effective from May 23, 2025, specifically address the transformation of post-consumer food-grade PET into FCM-rPET resins suitable for food contact applications. The scope covers acceptance criteria for FCM-rPET resin in Food Contact Materials and applies solely to FSSAI-approved recycling technologies, excluding non-food grade applications. The guidelines define key terms such as Food Authority, Manufacturer, Virgin PET (vPET), Post-Consumer food grade PET, PET Resin, and Recycled Polyethylene terephthalate (FCM-rPET). They outline approved recycling processes, including Super-Clean, Melt-in, Paste-in, and Chemical Recycling, each requiring a decontamination step. Conventional recycling processes without decontamination are not permitted for food contact materials. The document also specifies testing requirements, including Challenge Test, Extraction Test, and Migration Test, with FCM-rPET required to comply with relevant Indian Standards and be tested in NABL/ILAC accredited labs. Process requirements cover input material sourcing, validation through challenge or migration tests, and output monitoring to ensure quality and safety. Manufacturers must operate under Good Manufacturing Practices (GMP) and maintain comprehensive documentation, including Declaration of Compliance and Regulatory Opinion. Manufacturers of FCM-rPET are required to apply for authorization of their recycling process with FSSAI, providing detailed information about their facility, operational licenses, technology, and quality data. Authorized manufacturers will be registered on the FSSAI website and subjected to annual audits.
MINISTRY OF HEALTH AND FAMILY WELFARE
(FOOD SAFETY AND STANDARDS AUTHORITY OF INDIA )
NOTIFICATION
New Delhi, the 23rd May, 2025
F. No. SSDIVI-PF0SP20(16)/1/2025-Standard-FSSAI.—In exercise of powers conferred under clause (e) of sub-regulation (4) of regulation 4 of the Food Safety and Standards (Packaging) Regulations, 2018, the Food Safety and Standards Authority of India (FSSAI) hereby notify the following guidelines, namely: —
Guidelines for acceptance of recycled Polyethylene terephthalate (PET) as Food Contact Material (FCM-rPET)
1.SCOPE
This guideline:
-
- pertains only to the recycling process/operation of transforming post-consumer PET used for food applications into recycled PET as Food Contact Material (FCM-rPET) resins suitable for making Food Contact Materials.
- covers the acceptance criteria for using (FCM-rPET) resin in Food Contact Materials.
- applies only to recycling technology approved by FSSAI.
- does not apply to production of resins for non-food grade consumer applications.
2. DEFINITIONS
For the purpose of this guideline—
2.1 Food Authority – means the Food Safety and Standards Authority of India (FSSAI) established under section 4 of the Food Safety and Standards Act, 2006.
2.2 Manufacturer – means the operator of a recycling process and/or manufacturer of recycled Polyethylene
terephthalate (PET) as Food Contact Materials as per the recycling technology approved by FSSAI.
2.3 Materials
(1) Virgin PET (vPET) – Formed by poly-condensation reaction of ethylene glycol derived from ethylene and terephthalic acid derived from para-xylene as the starting monomers.
(2) Post-Consumer food grade PET – vPET and FCM-rPET Food Packaging material collected from households or by commercial, industrial and institutional facilities in their role as end-users of the product including returns of material from the distribution chain.
(3) PET Resin– an aggregate of fragments from grinding and washing of post-consumer PET/pre consumer industrial PET intended to be used for food applications.
(4) Recycled Polyethylene terephthalate (FCM-rPET) – Post consumer food grade PET resin that has undergone a validated decontamination process (as per requirements specified by national or international Regulatory Authority(s) to achieve specified purity for directly holding food.
2.4 Recycling Processes
Any one of the following recycling processes capable of producing Recycled PET as Food Contact Materials may be adopted. The recycling process adopted shall have at least one decontamination step capable of removing contaminants to a level of purity suitable for food contact:
(1) Super-Clean Recycling Process – a Conventional Recycling Process enhanced with an integrated decontamination step [as specified by FSSAI or any other Regulatory Body] to remove absorbed contaminants through a combination of surface treatment, high heat, and/or high vacuum in a controlled environment such that the output can be used for direct food contact.
(2) Melt-in Recycling Process– a virgin PET (v PET) production operation enhanced with the ability of incorporating PET Flakes in the molten form which is decontaminated through a combination of high heat and high vacuum.
(3) Paste-in Recycling Process – a virgin PET (v PET) production operation enhanced with the ability of incorporating PET Flakes in the paste form via partial glycolysis and equipped with an integrated system of removing absorbed contaminants via chemical distillation, vacuum degassing, etc.
(4) Chemical Recycling Process – a chemical reaction operation of pyrolysis or fully depolymerizing PET Flakes into purified ethylene glycol and terephthalic acid (or dimethyl terephthalate), or bis(2-hydroxyethylterephthalate). As per ISO 15270 guidelines, the purified depolymerized monomer can be deployed to produce polymer of virgin quality. The manufacturer of FCM-rPET using chemical recycling process shall submit application and relevant dossier to the Food Authority as per Form I.
For the purpose of this guideline, Conventional Recycling Process is defined as – a mechanical recycling operation where PET Flakes are washed, melted, extruded, and pelletized without a process step to remove contaminants. Such processes should not be used for manufacturing food contact materials as it does not have the decontamination process step.
2.5 Testing
(1) Challenge Test – a validation test in which virgin PET or Recycled Food Contact Material PET exposed to a mixture of chemicals of different molecular weight and polarity at specified levels, through the entire recycling process, and analyzed quantitatively for the residual concentrations. Challenge test needs to be repeated in case of changes in process, process parameters or input feed.
(2) Extraction Test – a quantitative analysis of substances present in recycled Polyethylene terephthalate (PET) as Food Contact Material (FCM-rPET).
(3) Migration Test – a quantitative analysis on the substances migrating from the vPET, or FCM- rPET resin containers into the food and shall adhere to the overall and specific migration limits specified for plastic materials intended to come in contact with food products.
Recycled Polyethylene terephthalate (PET) as Food Contact Materials (FCM-rPET) shall be tested in NABL/ILAC accredited Lab in compliance with IS: 12252, IS 9845, IS 9833 and amendments or latest versions thereof.
3. PROCESS REQUIREMENTS
The following requirements pertain to the operation of recycling processes mentioned in section 2.4.
3.1 Process Input
The process input shall be sourced in accordance with the minimum quality standard on FCM-rPET Resin. Input materials shall be controlled based on process validation criteria as identified by performance of the challenge test.
3.2 Process Validation
For the purpose of acceptance criteria following test shall be performed where applicable depending
on the technology used, as specified in any national or international regulatory body:
The level of decontamination shall be below the 220 µg/kg limit in the resin for each surrogate contaminant by a challenge test; or
The level of decontamination shall be below the 10 µg/kg limit in the food or food simulant for each surrogate contaminant by a migration test. The recycled Polyethylene terephthalate (PET) as Food Contact Material (FCM-rPET) shall conform to the specifications for polyethylene terephthalate (PET) i.e IS: 12252.
3.3 Process Output
The process output shall be subject to a monitoring program that ensures the continuity of Recycled Food Contact Material PET quality over time. The program shall include a chemical analysis by the process operator. The chemical analysis shall include either an extraction test on the Recycled Food Contact Material PET output or a migration test on the beverage bottles or food containers made with the FCM-rPET. The recycled Polyethylene terephthalate (PET) as Food Contact Material (FCM-rPET) shall conform to the specifications for polyethylene terephthalate (PET) i.e IS: 12252. The sensory analysis of FCM-rPET shall be conducted in accordance with ISO 13302 or equivalent.
3.4 Process Operation & Management
The recycling process shall operate under the principles of Good Manufacturing Practices, including the application of a quality assurance program as established by the manufacturer. Critical quality parameters must be defined to demonstrate the effectiveness of the decontamination process. Supply chain records and quality assurance data shall be maintained by the manufacturer to support product traceability and safety compliance.
4. ACCEPTANCE CRITERIA FOR FCM-RPET RESIN
As referred in section 3.2 and 3.3 of these guidelines.
5. MARKING & LABELLING
5.1 Food Contact Materials made of FCM-rPET resin shall carry the following:
(1) Symbol as shown below; and/or
X – percentage of recycled resin used
r- recycled
FCM- Food Contact Material
PET-polyethylene terephthalate
Information on the label as: – The packaging material is made with recycled PET.
(2) Any other requirement specified in national regulations shall also be complied with.
(3) The determination of recycled content shall be as per guidelines for recycling and recovery (IS: 14534:2023).
6. DOCUMENTATION
The FCM-rPET manufacturer, converters, beverage bottlers, food packers, FBOs (Food Business Operators) shall maintain and provide relevant documentation as specified in this section to their relevant downstream customer (converters, beverage bottlers, food packers/FBOs) & to the Food Authority as and when asked for.
a) Declaration of Compliance – a statement issued by the manufacturer declaring the FCM-rPET confirms to the specifications for polyethylene terephthalate (PET) i.e IS: 12252.
b) Regulatory Opinion – a NOC (No Objection Certificate)/NOL (No Objection Letter) issued by a recognized, competent authority addressing the capability of a given process to recycle post- Consumer Food Grade PET resin into FCM-rPET.
c) Supply chain records on product traceability and quality assurance data on safety compliance at each level of the food chain.
7. AUTHORIZATION
The manufacturer shall apply for authorization of the recycling process to the food authority by submitting necessary information as per FORM – I annexed. The manufacturer of r-PET resins shall be subjected to the annual audit of the manufacturing plant.
The Food Authority shall;
a) either authorize or reject the application, as per FORM-II, on the basis of the assessment,
b) register the authorized manufacturer of a recycling process/manufacturers of FCM-rPET from time to time on FSSAI’s website.
c) reserve the right to call for any information from the recognized manufacturer of a recycling process/manufacturers of FCM-rPET
Form – I
Application for authorization of FCM-rPET manufacturer
| S.No. | Particulars | Details/Documents |
| 1. | Manufacturer | Name, address of Premise# for which
application is being submitted, authorized personnel, etc. |
| 2. | Operational licenses | All licenses – factory, labour, pollution, GST etc. |
| 3. | Recycling technology | a) Details of the recycling technology & relevant documents of purchase or agreement made with the vendor (Technology & machine supplier).
d) Details of plant/machinery, make, material of construction and capacity, complete process flow chart and testing equipment, etc. |
| 4. | *Global Regulatory Approval | NOL/NOC/Safety Assessment |
| 5. | Validation done with Indian FCM-rPET | a) Facility approval/ clearance by Competent Authority
e) Vendor and internal audit reports to demonstrate the suitability & efficiency of the technology to produce FCM- rPET resin. |
| 6. | Quality& Safety related data | Test reports to confirm the quality & safety of the FCM-rPET as specified in Guidelines.
(Report shall be from a NABL accredited lab) |
| 7. | FCM-rPET compliance to
FSS(Packaging) regulations |
Test reports to confirm the quality & safety of the FCM- rPET (Report shall be from a NABL accredited lab)
a) FSS(Packaging) regulations 2018 – General requirement& Specific requirement pertaining to plastics [Refer to b) sensory analysis as per ISO 13302 or equivalent GMP/QMS certificates etc. |
| 8. | Declaration by the manufacturer | a) To declare that only post-consumer food packaging materials are used to manufacture FCM-rPET resin and to maintain records/details of the source, nature of feedstock along with the intended application (converters, beverage bottlers, food packers, FBOs) for every batch/lot. [Shall be maintained by FCM-rPET manufacturer]
b) To provide an audit report annually to demonstrate the capability of the technology & machinery to manufacture FCM-rPET as specified in Guidelines. c) To provide necessary documents/reports/ certificates/ FCM-rPET symbol compliance declaration as and when required by the Food Authority. d) Declaration to emboss the FCM rPET symbol on rigid plastic containers (FCM) and/or imprint the FCM rPET symbol on the flexible plastic pouches. |
* Global regulatory approval does not apply to manufacturing facilities producing FCM-rPET through the chemical recycling through monomer cycle process.
# Authorization for manufacturing FCM-rPET is granted based on the specific premises and production lines of the manufacturing facility.
Note: The Food Authority reserves the right to call for any information/further queries from the recycler at any point of time.
Authorization/Rejection of FCM-rPET
| Application No: | |
| Date of application: | |
| Name of the manufacturer: | |
| Name of the applicant: | |
| Registered address: | |
| Authorized person: | |
| Type of material being recycled: | |
| Approval/NOC/Details of technology: | |
| Status of application: | |
| Reasons for rejection, if any: |
Conditions for authorization*:
(i) The Food Authority reserves the right to inspect the records, premises and/or manufacturing & other related facilities of the applicant or manufacturing facility of exporting country prior/post authorization.
(ii) The recycled PET intended to be used as food contact material shall comply to all the criteria specified by
FSSAI (Ref.: No. with date_______________________________________ ) & rules and regulations made under the Food Safety and Standards Act, 2006 & as amended from time to time.
(iii) The applicant shall maintain all documents/records/details/certificates/audit & test reports as specified in the ‘Guidelines for acceptance of recycled Polyethylene terephthalate (PET) as Food Contact Material (FCM-rPET)’.
This issues with the approval of the Competent Authority.
Authorized Signatory
To,
M/s (Name & address of the manufacturer)
Note: * Conditions for authorization may change based on the application.
G. KAMALA VARDHANA RAO, Chief Executive Officer
[No. ADVT.-III/4/Exty./114/2025-26]
