How to Ensure Food-Grade PET Compliance in 2026

If you’re producing food packaging, bottles, or trays with PET resin, getting food-grade compliance right isn’t optional — it’s the price of entry. Rules are tightening in the U.S. and overseas, and brands won’t touch your packaging if you can’t prove your materials are safe. At CBRHK, we ship food-safe PET resin to beverage and packaging companies worldwide, so we see this firsthand. Here’s what you need to know to stay compliant this year.

What Makes PET “Food Grade” in the First Place?

Not all PET plastic is safe for food contact. That might sound obvious, but it trips up more companies than you’d think. Resin identification codes — the triangles made of chasing arrows — show the plastic type, not whether it’s certified for food contact; even common codes like PET (1) or PP (5) can be unsafe if made from non-compliant materials. A recycling symbol doesn’t equal a safety certificate.

So what does? PET’s safety in food contact is not assumed — it is regulated. In the U.S., the Food and Drug Administration (FDA) authorizes PET for food contact under Title 21 of the Code of Federal Regulations, where its composition, specifications, and limitations are well defined. The specific regulation for PET falls under 21 CFR 177.1630, which spells out exactly which polyethylene phthalate polymers, copolymers, and coatings are allowed to touch your food. If your PET resin doesn’t meet the requirements outlined there, it’s not food grade — period.

In Europe, the European Food Safety Authority (EFSA) handles similar oversight. EFSA applies the same principle, requiring recycling processes to pass challenge testing before authorization. And in practical terms, most global food companies now expect their suppliers to meet both U.S. and EU standards, regardless of where the packaging ends up. If you’re sourcing PET resin for food packaging sold in the U.S., you need to know the FDA framework inside and out. But if you’re exporting to multiple regions, plan for overlapping compliance from day one.

FDA Regulations and EU Standards for Food-Contact PET

Let’s get specific about what the FDA and EFSA actually require — because vague answers don’t pass audits.

For virgin PET resin, the FDA regulates it under 21 CFR 177.1630. PET plastic gets classified as GRAS by the FDA according to regulation 21 CFR 177.1630 following extensive testing on substance migration. This covers the polymer itself, any optional additives, and coatings applied to the base sheet or article. Your resin supplier should be providing a Declaration of Conformity (DoC) with every batch — if they’re not, that’s a red flag. For a resin to be certified as food-grade, it must be accompanied by a Supplier’s Declaration of Conformity (DoC), which guarantees that the material’s composition meets all regulatory requirements.

For recycled PET (rPET), the bar is even higher. The FDA authorizes PET for food contact under Title 21 of the Code of Federal Regulations. For recycled PET, FDA reviews each recycling process individually and issues a Letter of No Objection (LNO) only when a recycler proves that its process reliably removes contaminants. FDA sets a strict ceiling: any migration of a chemical from recycled packaging into food must not result in dietary intake greater than 1.5 micrograms per person per day, a level considered negligible risk. That 1.5-microgram-per-person-per-day threshold is non-negotiable, and it applies to every batch, every time.

On the EU side, Regulation (EU) No 10/2011 governs plastic materials intended for food contact. Acetaldehyde is a common PET contaminant generated during PET bottle manufacture. The specific migration limit (SML) of 6 mg/kg food set for this compound by the European Regulation No. 10/2011 is usually not exceeded. The regulation sets both overall migration limits (OMLs) and specific migration limits (SMLs) for individual substances like acetaldehyde, antimony, and terephthalic acid. If your PET resin is heading into beverage bottles for export, you’ll likely need to comply with both regulatory frameworks simultaneously.

And here’s what’s new in 2026: The Packaging and Packaging Waste Regulation 2025/40 (PPWR) entered into force on 11 February 2025 and will generally apply from 12 August 2026. This regulation brings mandatory recycled content targets and stricter sustainability requirements for all packaging entering the EU market. Producers must incorporate 30% recycled content by 2030 for PET beverage bottles (65% by 2040). This applies to plastic components constituting 5% or more of total packaging weight. Even if you’re a U.S.-based manufacturer, the PPWR affects you the moment you ship product to an EU customer.

Migration Testing: How to Prove Your PET Is Safe

Compliance isn’t just about buying the right resin — it’s about proving the finished packaging doesn’t leak anything harmful into the food it touches. That proof comes from migration testing, and it’s where a lot of companies stumble.

Migration testing simulates real-world contact between your PET packaging and food. Food-grade plastics undergo rigorous testing, including chemical migration tests to check for contaminants and thermal stability tests to ensure bottles withstand temperature changes. Labs use food simulants — like 4% acetic acid, 10% ethanol, or 3% acetic acid — to mimic acidic, alcoholic, or aqueous foods and check whether substances leach from the plastic into the simulant above safe limits.

For PET specifically, the main substances of concern are acetaldehyde, antimony (used as a catalyst), terephthalic acid, and oligomers. Acetaldehyde should be in the concentration range of 1 mg/kg in the bottle wall, otherwise the 10 µg/L migration limit might be exceeded. Acetaldehyde is a degradation product of PET and can be considered as the most important non-intentionally added substance (NIAS) in PET. While acetaldehyde doesn’t pose a health risk at low levels, it does affect taste — which is why bottled water companies especially are strict about keeping levels below 3 ppm in preforms.

Here’s a quick reference table for key PET migration limits:

For companies using recycled PET, the testing gets more involved. Manufacturers must undergo a “Challenge Test.” In this test, plastics intended for recycling are intentionally contaminated with surrogate substances. If the recycling and decontamination process successfully removes those contaminants to safe levels, the FDA issues a Letter of No Objection. Without that LNO, your rPET is not food grade, no matter what the label says.

How to Choose the Right PET Resin Supplier

Your compliance starts at the resin level. If you’re buying PET from a supplier who can’t provide full documentation — Certificates of Analysis, food-contact compliance certificates, migration test reports — you’re taking a gamble that no auditor or brand customer will tolerate.

Here’s what to demand from your resin supplier. First, ask for the FDA compliance documentation specific to the grade you’re purchasing. Request food-contact letters immediately. These documents, known as letters of guarantee, confirm that materials follow FDA rules, such as 21 CFR 177.1630 for PET. Second, ask for batch-specific Certificates of Analysis that cover intrinsic viscosity (IV), acetaldehyde content, color values, and moisture levels. Third, get EU Regulation 10/2011 compliance documentation if you plan to export.

At CBRHK, we build all of this into our standard supply process. Every batch of our bottle-grade PET resin comes tested and certified, with documentation covering FDA, EU, and other international food-contact regulations. We test intrinsic viscosity, color values, moisture content, and acetaldehyde levels before anything ships. Our bottle-grade specifications deliver high intrinsic viscosity for strong bottle walls and low acetaldehyde content for pure taste preservation — the two parameters that matter most for beverage packaging.

We also supply recycled PET (rPET) for companies working toward circular economy targets. With the EU PPWR now mandating recycled content in PET beverage bottles, having a reliable rPET source with proper food-contact documentation isn’t a nice-to-have anymore — it’s a business requirement. Our team provides processing parameters and troubleshooting support so you can optimize your production without guessing.

For manufacturers who also work with other polymers, we carry a full portfolio of thermoplastic resins. Our polypropylene offerings serve complementary packaging applications, and we provide the same level of compliance documentation across all materials.

Virgin PET vs. Recycled PET: Compliance Differences

The compliance path for virgin PET and recycled PET diverges in significant ways, and mixing them up can cost you.

Virgin PET resin is the simpler route. If it’s produced according to 21 CFR 177.1630 specifications and comes with proper supplier documentation, you’re largely covered for FDA compliance. The resin itself has predictable, consistent properties because it hasn’t gone through previous use cycles. Any plastic jars and beverage containers in your home are most likely made from PET. This material is used in 2-liter soda bottles, peanut butter jars, salad dressing containers and more. For applications that demand maximum clarity, top mechanical performance, or the broadest food-contact approval, virgin PET is the safest choice.

Recycled PET requires a different approach. Recycled polyethylene terephthalate (rPET) holds the most established food-contact approval infrastructure. PET also claims the highest global plastic recycling collection rate at approximately 29%, with EU member states exceeding 50% in several regions. For bottle-to-bottle applications, rPET pellets require intrinsic viscosity (IV) between 0.74 and 0.84 dL/g. Food-grade bottle applications typically require solid-state polymerization (SSP) to restore molecular weight lost during recycling. SSP also removes residual acetaldehyde, which must stay below 1 to 3 ppm for beverage packaging to prevent taste and odor issues.

The key compliance distinction: for rPET, the recycling process itself must be approved, not just the final resin. Challenge testing is the core validation protocol that separates legitimate food-grade recycled plastic pellets from marketing claims. A GRS (Global Recycled Standard) certificate proves recycled content but says nothing about food-contact safety. You need the FDA’s Letter of No Objection or EFSA authorization to use rPET in food packaging legally. If your end market is the United States, verify FDA NOL status. If your end market is the EU, demand EFSA scientific opinion and EC authorization with a valid EU Register entry. If you supply global brands like Coca-Cola, PepsiCo, or Unilever, prepare for both. These brand owners increasingly require documented FDA and EFSA compliance before accepting PCR packaging materials.

Documentation and Quality Assurance Best Practices

Compliance without documentation is just a claim. And claims without proof get your product pulled from shelves, your shipments quarantined, and your brand reputation damaged.

Build a documentation system that covers every step from resin procurement to finished packaging. At minimum, you should maintain supplier Declarations of Conformity, batch-specific Certificates of Analysis, migration test reports (both overall and specific migration), food-contact compliance certificates (FDA, EU, or both), and traceability records linking each batch of resin to its source. Batch testing to confirm compliance and traceability systems to track material sources are the two pillars that keep your compliance airtight.

Storage and handling matter too. Even if a plastic bottle meets food-grade standards, improper handling can compromise safety. PET resin should be stored in dry, cool conditions and kept sealed in original packaging until use. Properly stored PET resin stays stable for 12 months or more, but exposure to moisture degrades processing quality and can affect food-contact safety. Set up receiving inspection protocols at your facility — check packaging integrity, verify lot numbers against CoA documents, and confirm moisture levels before the resin ever hits your production line.

Strong supplier vetting includes food-contact letters, food-safety certifications, migration testing results, MSDS checks, and annual documentation updates. Red flags include vague safety claims, missing documentation, offshore suppliers without proper FDA records, and prices far below market rates. If a supplier offers PET resin at a price that seems too good, it usually is. Cutting corners on resin quality shows up in failed migration tests, off-taste products, or worse — a regulatory recall.

FAQs

Does PET plastic leach chemicals into food?

Under normal use conditions, food-grade PET shows very low chemical migration. PET plastic gets classified as GRAS by the FDA according to regulation 21 CFR 177.1630 following extensive testing on substance migration. The actual migration rates of its building blocks stay well under 0.01 mg per kg. As long as you’re using properly certified resin and not exposing packaging to extreme heat, PET is one of the safest food-contact plastics available.

Is recycled PET (rPET) FDA-approved for food contact?

Yes, but with conditions. While many plastics are only FDA compliant and food safe in their virgin state, recycled PET is an FDA-approved plastic for food contact. It also repels microorganisms and doesn’t corrode, making it an overall ideal material for food and beverage contact and storage. The recycling process itself needs an FDA Letter of No Objection. Always verify your supplier’s LNO documentation.

What migration tests are needed for PET food packaging?

You’ll need both overall migration testing and specific migration testing for substances like acetaldehyde, antimony, and terephthalic acid. The EU requires testing with food simulants under controlled time and temperature conditions. The FDA evaluates migration on a substance-by-substance basis under 21 CFR 177.1630.

How does the EU PPWR affect PET packaging sold in Europe?

The PPWR was published in the EU Official Journal in January 2025. The Regulation will enter into force on 11 February 2025 and will apply from 12 August 2026 throughout all EU countries, including any imported packaging. It introduces mandatory recycled content thresholds, stricter recyclability requirements, and new labeling rules that affect any company shipping PET packaging into the EU.

What acetaldehyde level is acceptable in food-grade PET?

Residual acetaldehyde should be less than 3 ppm in preforms for water packaging. The EU sets a specific migration limit of 6 mg/kg food under Regulation 10/2011. For beverages like mineral water where taste sensitivity is high, most manufacturers target even lower levels to avoid off-flavors.