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Codex Alimentarius Commission Requests Information on Possible Recycling Guidance; FDA Invites Feedback

Woman holding box of recycling

As noted previously in, the Codex Alimentarius Commission, a joint body of the Food and Agriculture Organization of the United Nations (FAO) and the World Health Organization (WHO), published a request for information through the publication of a Circular Letter (CL 2024/20-CAC), in March of this year, as it considers whether to develop guidance on the use of recycled material in food packaging. Recall that the U.S. delegation to Codex had proposed the investigation and possible development of recycling guidance by Codex in its November 20-24, 2023 meeting, linked in the CL at the “CRD01” reference.

The request for information is directed to Codex Members and official Observers, and includes general questions on whether it would be useful for Codex to develop the guidance and if responders would be interested in participating in work on the topic. It also includes questions about existing governmental and voluntary programs on the use of recycled materials in food packaging, whether those programs are dependent upon packaging types (e.g., plastic, metal, paper), and what types of technologies are currently approved or under development to ensure safety. In particular, Codex Members are asked, “Are you evaluating new, innovative recovery/recycling processes that could allow for the use of non-food contact materials to be used in food-contact packaging applications?” Chemical recycling technologies would be included in those processes. Also of interest to Codex is whether stakeholders have experienced issues regarding sufficient supply of feedstock of recycled material of suitable quality to fulfill demand, and whether stakeholders have experienced trade barriers that relate to recycling mandates or incorporation of recycled material into food packaging.

Stakeholders that have previously submitted requests for no objection letters (NOLs) to the U.S. Food and Drug Administration (FDA) for use of recycled material in food packaging have been invited by FDA to provide feedback in response to the CL directly to the Center for Food Safety and Applied Nutrition, at, by May 8, with the assurance that FDA will consider all comments in formulating its response to Codex Alimentarius. Of course, parties with access to an Observer Organization can also submit feedback through the Observer Organization.

The deadline for comments through an Observer Organization was originally May 1, 2024, but has been extended to May 15. Again, FDA is seeking feedback this week for possible incorporation into their official Codex response.