India’s Food Safety and Standards Authority has proposed two additions to the country’s rules for plastic materials used in food-contact packaging. The notification is dated November 2 and appeared in the November 3 Gazette. FSSAI invites comments for 60 days from the date the Gazette copies are made available to the public.
Proposed clause (f) would allow recycled polyethylene and polypropylene made through the monomer route of chemical recycling defined in IS 14534, provided the output is equivalent to virgin material and meets the applicable virgin-material criteria. Proposed clause (g) concerns recycled polymer derived exclusively from food-grade packaging and used in the outermost layer of multilayer food-contact packaging. Its inner layers must provide an adequate barrier against migration from the outer layer into food, and the packaging must satisfy the prescribed migration limits.
The two clauses call for different evidence
For the monomer route, ask the resin supplier to identify the recycling process and document how its output meets the applicable virgin-material criteria. For the multilayer route, ask for the feedstock origin, the layer specification and migration evidence for the finished structure. A resin dossier answers a different question from a barrier and migration dossier.
Teams can use the consultation to identify gaps in those dossiers and send comments to FSSAI. Any change to a food-contact purchasing specification should be assessed against the final notification and its commencement provisions when available.
If the proposals are adopted substantially as drafted, they could reward different supplier capabilities. A resin producer that can document virgin-equivalent output could spread the cost of building its evidence dossier across several customers using the same grade. A converter pursuing the outer-layer route would have to weigh any resin saving against the cost of qualifying the finished pack. The better starting point may be a high-volume pack with stable layer specifications and a traceable feedstock. A price comparison should account for testing and requalification alongside the resin quote. That comparison can guide which trials to budget for while the final scope and timing are still open.
Sources
Food Safety and Standards Authority of India — source document
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