Why new rule allowing recycled plastic in food packaging raises concerns

Synopsis: The new directive by Union environment ministry overrides 2016 rules that did not permit carry bags made of recycled plastic for food items.


Recently, the Union government notified the Plastic Waste Management (Second Amendment) Rules, 2021. The latest notification is a U-turn by the Centre and its stand of five years.

The use of recycled plastic was prohibited for food contact applications in the Plastic Waste Management Rules, 2016 whereas, the latest amendment allows carry bags made of recycled plastic or products made of recycled plastic for storing, carrying, dispensing or packaging ready to eat or drink foodstuff.

Note, it was only in 2018 that the FSSAI banned the use of recycled plastic or newspaper for packaging of food items.

What the concern w.r.t the Plastic Waste Management (Second Amendment) Rules, 2021?

Firstly, the new packaging regulations would compromise the food safety in India.

Secondly, wide public consultation was not done. For instance, following two major rules have been added to the Plastic Waste Management Rules without them being part of the Draft rules 2021.

the rules provided a moratorium of 10 years to big companies.

use of recycled plastics for food products introduced in the latest amendment.

Why using recycled Plastics in Food packaging is a problem?

Firstly, the unscientific methods used by the informal workforce to produce plastic pellets (used to make recycled goods) raise concerns, especially around the contamination and purity of the recycled plastic.

Secondly, Plastic is used in a variety of sectors ranging from medicines, electronic equipment to chemical fertilizers, which also raises the concern of the source of the recycled plastic that will be used in food contact applications.

Thirdly, standards for recycling of plastic have not been specified in the country, making it all the more difficult to understand the chemical conformity of the recycled plastic.

Fourthly, research has proven that as plastics are recycled, its molecular integrity gets compromised. This may further the possibility of ‘legacy chemical’ migration from plastics to food. So, the possibility of presence of poisonous substance in recycled plastic bags can never be completely ruled out.

Fifthly, it is practically impossible to tell the amount of recycled plastic that has been added to the final product. This may give the big players a way out to keep using virgin polymers and endless use of recycled Plastic.

Must Read: How recycled plastic is regulated globally?
What is the way forward?

Before the FSSAI takes a call to include recycled plastic for food contact applications, we have to ensure the following things:

Our plastic has to be recycled in authorised recycling facilities. The country’s data around the number and capacity of plastic recycling plants is very weak. We need a yardstick to understand our capacity to recycle correctly and utilise the material for other applications.

The use of recycled plastic should have been mandated for non-food applications initially. This will help us to understand the issues faced by the industries in terms of production and social acceptability.

An inventory needs to be created of the types of processes that we have in the country to recycle our plastics. Then, we need to identify the plastic recycling processes that are safe enough to produce recycled plastic that can be used for food contact applications.

Guidelines are required for the use of recycled plastic for packaging of ready-to-eat food materials. This should include the source of the post-consumer plastic waste, type of polymer that can be used, the nature of the food material that they can be used for packaging, etc.,

Finally, a working mechanism needs to be developed with all the stakeholders such as MoEFCC, FSSAI, the Central Pollution Control Board, Urban Local Bodies etc.

Source: This post is based on the article “Why new rule allowing recycled plastic in food packaging raises concerns” and “Recycled plastic for food packaging: Why the new rules are shocking” published in DTE on 1st Oct 2021.

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