Across Asia, governments are advancing circular economy measures and recycled-content policies for packaging. The ambition is right since food contact materials (FCMs) do essential work in protecting food safety, preserving quality and shelf life, and reducing food loss, and recycling them responsibly matters.
At the same time, the regulation of FCMs remains fragmented, with national frameworks differing in definitions, documentation requirements, migration testing approaches and authorisation pathways. Recycled materials are the subject of growing policy ambition, yet few markets have clear food-safety criteria for when recycled content may safely touch food. That gap is now the most pressing question in food packaging regulation in the region.
The instinct in regulatory circles is to wait; build a comprehensive food contact framework first, then deal with recycled materials inside it. FIA's view is that this sequencing is wrong. Asia should pursue practical convergence on recycled FCMS (r-FCMs) now, as the starting point rather than the end point of regional alignment.
National authorities must keep responsibility for food-safety decisions, and nothing in this argument changes that. But the region does not need identical rules before it can agree on how to assess this one category of material. The goal is outcome-based regulation, not uniformity.
Starting with recycled materials is achievable because the safety questions they raise are finite and well understood. What was the source of the feedstock, and was it suitable for food contact recycling? Was it sorted and protected from contamination? Has the decontamination process been validated? Are non-intentionally added substances (NIAS) understood and managed? Does migration testing support the intended use? Food safety of r-FCMs is paramount. Recycled materials have a unique risk profile and therefore require new food safety and quality assurance protocols in addition to those existing for virgin materials. The fact that a material is recycled should not, by itself, decide whether it is acceptable. The safety evidence should.
Still, the pieces for convergence already exist. Japan has moved its food contact regulation to a positive-list system with a grace period until 2030, and such positive lists and scientific assessments are likewise maintained in the European Union’s Regulation (EC) No 1935/2004 and the relevant specific measures, the United States’s Title 21 of the Code of Federal Regulations and Canada’s Lists of Acceptable Polymers For Use in Food Packaging Applications. These can serve as initial reference points where the scientific basis is relevant and the intended use is comparable.
Relying on a credible existing evaluation is not automatic acceptance; it is a way for national authorities to focus their own assessment capacity on genuine risk rather than re-examining what trusted regulators have already established. Codex, meanwhile, has opened a discussion on recycled plastics in food packaging. If Asian regulators engage early, future international guidance will reflect Asian supply chains, regulatory capacity and implementation realities. If they wait, it will be written around someone else's.
For companies, the cost of fragmentation is concrete. A recycler that validates its decontamination process in one market cannot carry that evidence next door. A manufacturer preparing technical dossiers faces different definitions of the same material in each jurisdiction. Migration testing is repeated rather than recognised. That uncertainty falls hardest on small and medium enterprises (SMEs) and domestic suppliers, and it deters exactly the investment in food-grade recycling capacity that recycled-content policies depend on. To be clear, this is not an argument for lighter regulation of recycled materials. Clear, demanding criteria are what allow recycled content to scale safely; their absence is what holds it back.
None of this requires every market to move at the same speed. Regulatory systems across Asia are at different stages of development, and a workable approach should be phased, supported by technical guidance, training and laboratory strengthening where capacity is still being built. Structured dialogue between regulators and industry should be part of that support.
r-FCMs bring together food safety, sustainability and trade in a single regulatory question, which is precisely why they are the right place to start. Asian regulators should use the current Codex discussion to align on practical principles: feedstock control, traceability, decontamination validation, migration testing, the treatment of NIAS, and the appropriate use of trusted scientific assessments.
FIA is ready to support that work with practical experience from regional supply chains, evidence from recycled-content pilots, and migration and exposure data where appropriate. And the prize is a regulatory environment that protects consumers while giving recycled content a credible, predictable pathway into food packaging.