FDA PCR Plastics NOL Trends in Q4 2025–Q1 2026: What Food-Grade Recycled Plastic Suppliers Should Know

FDA NOL in Context: A Process- and Use-Specific Opinion

An FDA No Objection Letter for recycled plastics is not a conventional certification or universal market approval. In practical terms, it is FDA's favorable opinion regarding the suitability of a specific recycling process to produce PCR plastic of suitable purity for defined food-contact applications. FDA's Recycled Plastics in Food Packaging page explains that FDA considers proposed uses of recycled plastic on a case-by-case basis and provides informal advice on whether the recycling process is expected to produce PCR plastic of suitable purity for food-contact applications.

This distinction matters because a NOL is generally tied to the polymer, source and control of PCR feedstock, recycling process and process parameters, contaminant-removal evidence, intended food type, Conditions of Use, and any limitations on recycled content, food-contact layer, or multilayer structure. Companies should also review whether the recycled material and finished article are supported by applicable food-contact authorizations, such as relevant 21 CFR food additive regulations, effective Food Contact Notifications, or other applicable exemptions.

For this reason, companies should not treat one NOL as automatically covering all food packaging applications. The actual commercial use should be checked against the scope and limitations of the relevant FDA opinion letter, and the result should be aligned with customer documentation, U.S. Declaration of Compliance support for food contact materials, and broader U.S. FDA Food Contact Materials Compliance Services | 21 CFR Review.

14 FDA PCR Plastics NOL Entries Reviewed: Key Trends

The 14 reviewed FDA PCR plastics NOL entries from Q4 2025 through Q1 2026 suggest several practical trends for companies planning U.S. food-contact applications. The records should be interpreted together with FDA's Guidance for Industry: Use of Recycled Plastics in Food Packaging (Chemistry Considerations) and the company's own intended-use strategy.

Reviewed FDA PCR Plastics NOL Entries: Q4 2025-Q1 2026

The table below provides a simplified summary of selected FDA PCR plastics NOL records. Companies should refer to the FDA PCR plastics database and the corresponding NOL files for exact use limitations, recycled content percentages, food types, Conditions of Use, and barrier requirements. Records are sorted by FDA Recycle Number from Z to A.

Key Compliance Takeaways for PCR Plastics and Food Packaging Suppliers

1. Feedstock source control and traceability are the starting point

FDA typically expects a complete description of the source of PCR plastic and the source controls designed to ensure that only suitable input material is recycled. Companies should prepare supplier qualification records, feedstock source statements, incoming inspection procedures, sorting and contamination control records, batch traceability documentation, and specifications for accepted and rejected materials. These materials are also useful when preparing buyer-facing Declaration of Compliance documentation for U.S. food contact materials.

For mixed-source PCR streams or feedstock with limited traceability, the data burden may increase. Companies should check whether their source control logic matches FDA's recycled plastics guidance and the relevant 21 CFR or FCN authorization basis for the original food-contact articles.

2. The recycling process description should be technically specific

A general process flowchart is usually not enough. Companies should be ready to describe sorting, washing, grinding, extrusion, filtration, deodorization, pelletizing, or other key steps, as well as critical process parameters, equipment configuration, monitoring points, quality control points, and batch release criteria. REACH24H's FDA NOL application support can help organize these process details into a technical dossier structure suitable for FDA communication.

If a company operates multiple lines, equipment models, or process settings, it should assess whether one submission strategy can reasonably cover all variations. Otherwise, commercial expansion may require additional justification or a separate strategy.

3. Contaminant-removal evidence should match the polymer and intended use

PCR plastics may present potential contaminant risks. Depending on the polymer, process, feedstock control, and intended use, companies may need to support the process with surrogate contaminant testing, migration testing, or scientific justification based on process design and source control. FDA's recycled plastics guidance provides chemistry considerations for evaluating recycled plastics used in food packaging.

Testing should not be commissioned before the target use and submission strategy are clear. Otherwise, companies may face data gaps, mismatched test conditions, or evidence that cannot support the desired NOL scope. Companies may combine testing strategy design with U.S. FDA FCM compliance review to ensure that the polymer, intended use, and supporting authorization route are aligned.

4. Intended use and NOL scope should be aligned before submission

A NOL strategy should start with the commercial use case. Before submitting, companies should define food types, Conditions of Use, contact temperature and duration, single-use or repeated-use applications, direct food-contact layer or non-food-contact layer, recycled content level, effective barrier considerations, and article type, such as bottles, trays, films, caps, containers, tableware, or multilayer structures.

This is important because the NOL scope may not automatically cover a customer's actual use. A company may hold, license, or reference a NOL, but still fail a buyer review if the intended use is outside the NOL limitations. Where the material or component itself requires a different authorization route, companies should assess whether a U.S. FDA Food Contact Notification (FCN) or other food contact substance authorization is relevant.

5. Use of another company's NOL should be verified carefully

If a listed process is sublicensed to another manufacturer, the sublicensing company may not need a new favorable opinion letter in its own name if the recycling process and intended use conditions are exactly the same as those described in the original favorable letter. However, companies relying on another party's NOL should verify whether the process, equipment, parameters, feedstock source, intended use, and licensing arrangement are fully aligned.

For supplier qualification, the NOL should be reviewed together with technical dossiers, food-contact authorization evidence, supplier declarations, and U.S. importer documentation. REACH24H can support supplier document review as part of U.S. recycled plastic food packaging compliance.

Who Should Review FDA NOL Readiness Early?

Practical Preparation Checklist Before an FDA NOL Submission

• Define the target use before testing, including food type, Conditions of Use, temperature, contact duration, recycled content, and layer structure.

• Build source control documentation early, including supplier records, batch logs, incoming material checks, and proof that the feedstock comes from food-contact articles where required.

• Confirm whether existing data, surrogate contaminant testing, migration testing, or other evidence can support the intended use under FDA's recycled plastics guidance.

• Assess whether different production lines, process parameters, or equipment models can be covered under one submission strategy.

• Compare the intended commercial application against the NOL scope before using the NOL in customer audits or supplier qualification.

• Review broader U.S. food contact compliance, including applicable 21 CFR requirements, FCNs, DoC documentation, and customer-specific supply chain evidence.

• Align the expected NOL timeline with product development, customer review, U.S. importer onboarding, and export planning.

How REACH24H Can Support FDA PCR Plastics NOL Projects

REACH24H provides FDA NOL support for recycled plastics used in U.S. food-contact applications. During the reviewed Q4 2025-Q1 2026 period, four of the 14 FDA PCR plastics NOL entries were projects supported by REACH24H, covering key polymers such as PP and HDPE.

REACH24H can support companies with:

• FDA recycled plastics NOL applicability assessment for PCR PET, PP, HDPE, LDPE, LLDPE, and multilayer packaging applications;

• PCR plastics food-contact compliance pathway review under FDA's recycled plastics guidance, 21 CFR, FCN, and customer documentation requirements;

• Feedstock source control and process data gap analysis for source traceability, sorting, decontamination, and batch control evidence;

• Intended use, food type, Conditions of Use, and recycled-content strategy before testing or dossier preparation;

• Surrogate contaminant testing strategy and project oversight to reduce mismatched testing conditions or insufficient evidence;

• English technical dossier preparation and review for FDA communication and customer-facing technical support;

• FDA communication, follow-up, and supplemental response support during the review process;

• Customer-facing documentation for U.S. food packaging supply chains, including NOL scope interpretation, U.S. DoC support, supplier qualification evidence, and import compliance documentation.

For companies planning to use PCR plastics in U.S. food packaging, an early FDA NOL readiness review can help reduce rework, clarify submission scope, and improve preparedness for customer qualification. Companies operating across multiple regions may also need to coordinate their U.S. NOL strategy with ASEAN food contact materials compliance or other regional recycled plastic packaging rules.

FAQ

Recommended Reading

• FDA No Objection Letter (NOL) for Recycled Plastics in the U.S.

• U.S. FDA Food Contact Materials Compliance Services | 21 CFR Review

• Guidance for Regulatory Compliance of Recycled Plastics for Food Packaging in the U.S.

• U.S. FDA Food Contact Notification (FCN) Application - A Complete Guide

• Navigating Declaration of Compliance (DoC) for Food Contact Materials in the U.S.

Related Services

• U.S. FDA No Objection Letter for Recycled Plastics

• U.S. Food Contact Materials Compliance Services

• U.S. Food Packaging Compliance for Recycled Plastics

• U.S. FDA Food Contact Notification Application

• U.S. Declaration of Compliance for Food Contact Materials

• ASEAN Food Contact Materials Compliance Services

Official References

• FDA: Recycled Plastics in Food Packaging

• FDA: Submissions on Post-Consumer Recycled (PCR) Plastics for Food-Contact Articles

• FDA: Guidance for Industry - Use of Recycled Plastics in Food Packaging (Chemistry Considerations)

• FDA: Food Contact Substance Notification Program

• FDA: Inventory of Effective Food Contact Substance Notifications

• FDA: Food Types and Conditions of Use for Food Contact Substances

• eCFR: Title 21, Chapter I, Subchapter B - Food for Human Consumption