recycled plastic in food packaging

“Why is there concern about a new rule allowing recycled plastic in food packaging?” The Union government published the Plastic Waste Management (Second Amendment) Rules 2021 on September 22, 2021. This occurred just weeks after the first amendment, which listed 20 single-use plastic items to be phased out, on August 12, 2021.

The current notification is contradictory to the Centre and its stand of five years. 

The use of recyclable plastic in food contact applications was not permissible by the Plastic Waste Management Rules, 2016: Carry bags or products that come of recyclable plastic are not in use for storing, carrying, dispensing, or packaging ready-to-eat or drink foodstuffs, as per the clause b, sub-rule 1, rule 4.

This proposal did not say in the Draft Plastic Waste Management Rules, which was come in March 2021.

The current amendment was notified under the sub-rule 4 of rule 5 of the Environment Protection Rules, 1986. It said

Carry bags made of recyclable plastic or products that come of recyclable plastic can come in use for storing, carrying, dispensing, or packaging ready-to-eat or drink foodstuffs. Subject to the Food Safety and Standards Authority of India’s notification of appropriate standards and regulations under the Food Safety and Standards Act, 2006. (FSSAI).

In 2018 did the FSSAI declare that the use of recyclable plastic or newspaper for food packaging would be permissible from July 1, 2019? Pawan Agarwal, the former CEO of FSSAI, stated that “the new packaging regulations would raise the bar of food safety in India to the next level.”

Ideally, the FSSAI, as the country’s competent authority for food safety. Should have initiated the discussion by amending their policy, and the Ministry of Environment, Forest, and Climate Change (MoEFCC) should have followed suit.

The Union government’s stance and approach in notifying this amendment are difficult to comprehend.

Therefore, two major rules have come in addition to the Plastic Waste Management Rules. That does not include in the Draft Rules 2021. This shows that there was no public consultation on these two issues.

However, before the FSSAI takes a call to include recycled plastic for food contact applications. They have to ensure the following things:

To understand the issues faced by industries in terms of production and social acceptability. The use of recyclable plastic should be necessary for non-food applications first.

An inventory of the types of processes that we have in the country to recycle our plastics must improve. After that, the plastic recycling processes are safe enough to produce recycled plastic. Which can be in use for food contact applications will need identification.

Recommendations for India

For the use of recyclable plastic in the packaging of ready-to-eat food materials, there is a need for guidelines. This should include the source of post-consumer plastic waste. The type of polymer that can be usable, and the type of food material which we are using.

A working mechanism must be developed in collaboration with all stakeholders, including but not limited to the MoEFCC, FSSAI, the Central Pollution Control Board, all State Pollution Control Boards and Pollution Control Committees, the Urban Local Bodies, plastic industry representatives, including the plastic recycling industry, and consumers.

This will allow us to devise a logical solution for the use of recycled plastic.