Food-grade rPET in India: what FSSAI now allows

This page explains a regulatory position, not our legal advice. Rules in this area are moving and the responsibility for a food pack sits with the brand owner. Verify the current text with FSSAI or your regulatory consultant before you specify anything.

What did FSSAI actually change in 2025?

It published guidelines for the acceptance of recycled PET as a food contact material — the FCM-rPET guidelines, issued in May 2025. They set out which recycling technologies are acceptable, what has to be proved by testing, and what documentation has to follow the material down the supply chain.

Before that, the working position for anyone specifying food packaging in India was straightforward: recycled plastic did not go into direct food contact. That default kept things simple and it kept recycled material out of a very large category of packaging. What the guidelines do is replace a blanket answer with a conditional one. Recycled PET can now be used for food contact — if it was made a particular way, tested a particular way, and documented a particular way.

The scope is narrow and worth stating precisely. The guidelines address the recycling of post-consumer food contact PET into FCM-rPET resin. They are about PET. They do not open a route for recycled PVC, recycled polystyrene or recycled polypropylene in food contact, and no amount of enthusiasm about the circular economy changes that. If your pack is HIPS and it touches food, this document does not help you.

The second thing worth stating precisely: the approval attaches to the recycling process, not to the tray. It is earned upstream, by the recycler and the resin producer, and then carried downstream on paper.

Which recycling routes are allowed, and which are not?

Four routes qualify — super-clean, melt-in, paste-in and chemical recycling — and each must include an integrated decontamination step. Conventional recycling that washes, melts, extrudes and pelletises PET flakes without decontamination is explicitly not permitted for food contact material.

That last sentence is the whole regulation in one line, and it is the sentence a brand needs to internalise. The bottle-flake-to-sheet process that supplies most ordinary recycled packaging in India is not, on its own, a food-contact process. It produces perfectly good rPET for a display tray or a dunnage insert. It does not produce FCM-rPET.

Input material matters too. The feedstock is expected to be post-consumer food contact PET meeting minimum quality criteria, controlled against the conditions under which the process was validated. A recycler cannot validate on clean bottle flake and then quietly run mixed post-industrial waste.

What is a challenge test, and why does it decide everything?

A challenge test proves the decontamination actually works. PET is deliberately spiked with surrogate chemicals spanning a range of molecular weights and polarities, run through the complete recycling process, and the residue left in the output is measured.

The logic is elegant. You cannot test for every contaminant a used bottle might have picked up in the years before it reached a recycler, so instead you contaminate the input on purpose with substances chosen to behave like the plausible worst cases — small and volatile, large and heavy, polar and non-polar — and you measure how much of each survives the process. If the process strips the surrogates, it will strip the real thing.

The guidelines set the acceptance criterion at 220 µg/kg in the resin for each surrogate contaminant by challenge test, or alternatively a demonstrated migration of no more than 10 µg/kg into food or a food simulant. Two supporting tests sit alongside it: an extraction test, which quantifies what is present in the FCM-rPET resin, and a migration test, which quantifies what actually moves out of the material into food or a simulant.

All of this must be done in NABL or ILAC accredited laboratories. And critically, the challenge test is not a one-time certificate to be framed and forgotten — it must be repeated whenever the process or the input material changes, with the output monitored by regular chemical analysis in between.

Which Indian Standards does the paperwork sit on?

Four, plus one ISO standard for sensory evaluation. They are cited by number in specifications and purchase orders, so it is worth knowing which does what rather than copying them blindly into a document.

Use the current version of each. Standards are revised, and a certificate citing a superseded edition is a finding waiting to happen at your next audit.

What is a Declaration of Compliance, and what must it say?

A DoC is a written statement from the manufacturer confirming that the FCM-rPET conforms to the applicable specification — in practice, to IS 12252 — supported by the underlying test evidence and by supply chain records that make the material traceable.

A DoC is not a marketing certificate and it is not a letter saying the material is "food grade". A useful one names things. It should identify the specific grade and the manufacturer, state the standard it complies with, describe the conditions of use it covers — what food types, what temperature, what contact time — and be signed by someone with the authority to mean it.

Around it, the guidelines expect the manufacturer to operate under Good Manufacturing Practices with a documented quality assurance programme, to record critical process parameters, to maintain traceability records through the supply chain, and to undergo annual plant audits. Authorised producers may use the FCM-rPET symbol showing the recycled percentage, alongside the statement that the packaging material is made with recycled PET.

The word to hold on to is chain. A DoC on its own proves very little. A DoC that connects to a named resin, from a named process, with test reports and batch records that reach your delivery note — that is a compliance file.

What documents should a brand demand from a converter?

Six, and you should ask for them before tooling rather than before dispatch. Every one of them exists upstream of the thermoformer, so a converter can only pass them on — which is exactly why you should test whether they can.

One practical test, worth more than any questionnaire: ask for the file on a Monday. A supplier who already works this way sends it within the week because the documents exist and sit in a folder. A supplier who has never been asked will take a month, because the month is spent obtaining them. Both may end up compliant. Only one of them was compliant before you asked.

How does this interact with the recycled-content mandate?

They pull in the same direction and are governed by completely different rules. Extended producer responsibility obligations push recycled content into rigid plastic packaging on a rising schedule; the FSSAI guidelines govern whether that recycled content may touch food. Meeting one does not satisfy the other.

Under the plastic waste rules, rigid plastic packaging — Category I, which is where thermoformed trays sit — carries the steepest recycled-content obligation, rising over several years:

The 2026 amendment to the rules did not soften those percentages. It changed how a shortfall is handled: an unmet target can be carried forward for up to three years provided at least a third of the deficit is cleared annually, and obligations can be met through a tradable certificate mechanism rather than by recycling directly. Check the current position and your own category before you rely on any of this — the detail is in recycled content rules in India.

Now put the two regimes side by side and the squeeze is obvious. A confectionery brand has a rising recycled-content obligation on its rigid packaging. Its rigid packaging is a thermoformed insert tray. If that tray touches unwrapped product, the recycled material in it has to come through the FCM-rPET route, which is a much smaller supply base than ordinary rPET. If the product is individually wrapped, the tray is not in direct food contact and the ordinary rPET supply serves.

Does this mean every rPET tray is now food-safe?

No. Most rPET sheet on the Indian market is made by conventional mechanical recycling without a validated decontamination step, which the guidelines exclude from food contact. Ordinary rPET remains excellent packaging — for products that are not food, or for food that is already wrapped.

Three distinctions decide where a tray falls:

• Direct versus indirect contact. A tray holding unwrapped biscuits is in direct contact. A tray holding individually wrapped chocolates is not touching food at all; it is touching a wrapper. That is a materially different regulatory conversation and it is the reason a great many confectionery inserts can use ordinary recycled sheet today.
• Contact conditions. Migration depends on what the food is, how hot it gets and how long it sits there. A cold, dry, short-contact application is a far easier case than a fatty food in prolonged contact. Migration test conditions must match your real use, not a convenient one.
• Layer structure. Some sheet is built with a virgin skin over a recycled core. Whether that construction functions as a barrier for regulatory purposes is a question for the sheet manufacturer's documentation and your regulatory adviser — not an assumption to make on a specification sheet.

The honest summary for a buyer: recycled PET for food contact is now possible in India, is not yet ordinary, and requires you to check the chain rather than trust the label.

What does this mean for thermoformed food trays and confectionery inserts?

For inserts that hold wrapped product, very little changes and recycled sheet is already the sensible default. For trays in direct contact with food, the specification now has to name the sheet's FCM-rPET status at design stage, because it decides which sheet you can buy.

Practically, that reshapes the order in which decisions get made. It used to be: design the tray, choose the gauge, then sort the paperwork. Now the sequence for a food-contact pack is:

1. Establish the contact condition first. Direct or through a wrapper? Dry, fatty or moist? What temperature and for how long? This one answer determines the whole material path.
2. Confirm sheet availability before tooling. Find out whether sheet with the required documentation exists in the gauge and clarity you need. Tooling built around a sheet you cannot source is an expensive lesson.
3. Fix the recycled-content target separately. Your EPR obligation applies across your whole rigid packaging portfolio, not tray by tray. Sometimes the sensible answer is to carry a higher recycled percentage on the non-food packs so a difficult food-contact pack does not have to.
4. Then design the tray. Footprint, draw depth, cavity layout, gauge. That part has not changed at all — see what a thermoformed tray costs per piece.

The good news for the second point is that a thermoforming tool is cheap and quick to make, and quicker still to change if a material has to move. That flexibility is worth real money in a regulatory area still settling down.

What can Eagle Thermo supply today?

We form A-PET, rPET, PVC and HIPS from 200 to 2000 micron, and both the rPET and the HIPS we run are recycled as standard, supplied with a self-certified recycled-content declaration. For direct food contact we work to the sheet documentation available for the specific grade.

Being precise about our own position, because precision is the point of this whole article:

• Recycled content: standard, not a premium option. Over half our total output runs on recycled material, with a self-certified declaration. That is a self-certification, not a third-party certificate, and we describe it that way.
• Food contact: handled per grade and per application, on the strength of the sheet manufacturer's documentation. We will not describe a tray as food-grade because the polymer happens to be PET.
• Current FCM-rPET sheet availability, the grades we can source and their documentation status: CONFIRM — a short statement of which food-contact recycled grades we can actually buy today, in which gauges, to be confirmed with our sheet suppliers and refreshed periodically.
• Forming environment: a controlled forming room with filtered air, gowning, restricted entry, segregated material handling and batch traceability. It is a controlled environment, not a formally ISO-classified cleanroom, and we never claim an ISO class.
• Traceability: batch records that connect a delivered carton to the sheet lot it was formed from — the record a food auditor will actually ask for.

If a project needs something we cannot document, we would rather say so at the enquiry stage. Twenty-seven years of forming has taught us that the expensive failures are the ones discovered at the customer's audit, not the ones discovered on a phone call.

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