REACH24H Consulting Group has supported a recycled plastics manufacturer in obtaining a No Objection Letter (NOL) from the U.S. Food and Drug Administration (FDA) for a food-grade recycled polypropylene (rPP) physical recycling process. The rPP material covered by the NOL may be used at levels up to 100% recycled content in articles intended to contact dry foods under FDA Conditions of Use E through G, covering room-temperature to frozen-temperature applications. For companies targeting the U.S. food-contact packaging market, this case highlights the importance of process-specific FDA NOL review for recycled plastics.
FDA NOL for Recycled Plastics: What Companies Should Know
For post-consumer recycled (PCR) plastics intended for food-contact use, FDA evaluates whether a specific recycling process can produce recycled plastic of suitable purity for the intended application. The review focuses on the recycling process, PCR feedstock control, potential contaminant removal, and proposed food-contact conditions.
An FDA No Objection Letter is therefore process- and use-specific. It should not be understood as a general approval of the recycled polymer materials, nor should it be applied to different processes, feedstock sources, food types, temperatures, or end-use conditions without further assessment.
For packaging converters, food brands, resin suppliers, and importers, the key compliance question is whether the actual product application falls within the scope reviewed by FDA.
Why Food-Grade Recycled Polymer Matters
Demand for recycled-content packaging continues to grow as food brands and packaging manufacturers pursue sustainability and circular economy goals. However, recycled plastics used in food-contact articles must meet higher compliance expectations than materials used in non-food applications.
The FDA NOL pathway for food-grade recycled polymer shows that recycled plastic can support regulated food-contact packaging applications when the recycling process, feedstock control, and intended use conditions are properly substantiated.
This is particularly relevant for companies seeking to:
Use recycled-content materials in food-contact packaging;
Support sustainability and circular packaging commitments;
Strengthen supplier qualification and customer documentation;
Enter or expand in the U.S. food packaging market;
Provide clearer technical evidence for recycled plastic compliance reviews.
Impact & Actionable Advice for Global Companies
Companies developing, purchasing, or using recycled polymer for U.S. food-contact applications should avoid assuming that all PCR or recycled materials are automatically suitable for food use. The compliance status of recycled plastics depends on the reviewed process and the defined conditions of use.
Before using or sourcing recycled polymer for food-contact packaging in the U.S., companies should:
Verify whether the recycling process has an applicable FDA NOL;
Confirm the covered polymer type, feedstock source, recycled content level, food type, and temperature range;
Check whether the intended application matches the stated conditions of use;
Review available data on feedstock control and decontamination performance;
Prepare documentation for customer audits and regulatory due diligence;
Avoid broad claims such as "FDA-approved recycled PP" if they exceed the NOL scope;
Assess whether additional compliance work is needed for other target markets, such as the EU, China, or Japan.
For international supply chains, this due diligence is especially important. A supplier's NOL should be reviewed carefully before it is relied on for U.S. food-contact applications.
How REACH24H Can Help
REACH24H provides regulatory consulting support for recycled plastics intended for food-contact applications, including U.S. FDA NOL strategy and dossier preparation. Our Food Contact Materials team supports recycling companies, material manufacturers, equipment providers, packaging converters, and brand owners in assessing regulatory pathways and preparing technically robust submissions.
Our services include:
FDA NOL applicability assessment for recycled plastics;
Regulatory strategy for rPP, rHDPE, rPET, rLLDPE, and other PCR plastics;
Review of feedstock sources, source control measures, and recycling process information;
Technical data gap analysis and testing strategy support;
Coordination of surrogate contaminant testing, migration testing, or migration modeling where appropriate;
Dossier preparation and FDA communication support;
Review of intended use conditions and downstream customer documentation;
Cross-market compliance support for recycled plastics in the U.S., EU, China, Japan, and other key jurisdictions.
With experience in food contact materials, recycled plastics, and global market access, REACH24H helps companies align sustainability objectives with regulatory compliance requirements.
Planning to use or supply recycled plastics for food-contact packaging in the U.S. market? Contact REACH24H to assess your FDA NOL strategy and identify the appropriate compliance pathway for your recycled plastic materials.
