The purpose of this document is to highlight the chemistry issues that FDA recommends that a manufacturer of recycled plastic consider during the manufacturer's evaluation of a recycling process for producing material suitable for food-contact applications. This document supersedes the December 1992 “Points to Consider for the Use of Recycled Plastics in Food Packaging: Chemistry Considerations” (1992 “Points to Consider”). The possibility that chemical contaminants in plastic materials intended for recycling may remain in the recycled material and could migrate into the food the material contacts is one of the major considerations for the safe use of recycled plastics for food-contact applications. Other aspects of plastics recycling, such as microbial contamination and structural integrity of the recycled plastic, are also important, but are not discussed in this document.
FDA's guidance documents, including this guidance, do not establish legally enforceable responsibilities. Instead, guidances describe our current thinking on a topic and should be viewed only as recommendations, unless specific regulatory or statutory requirements are cited. The use of the word should in FDA guidances means that something is suggested or recommended, but not required.
