Recycling food packaging: Anvisa answers questions

The Brazilian Health Regulatory Agency (Anvisa) recently released the 6th edition of its Questions and Answers document on materials in contact with food. This updated version incorporates changes resulting from regulatory updates and has been adjusted to provide clearer responses.

New topics covered in the document include:

  • Chemical recycling of plastic materials
  • Biodegradable or compostable packaging
  • References for updating positive lists
  • Woods and fabrics for food contact
  • Expanded polystyrene
  • Water tanks
  • Migration testing in cans
  • Use of salts not listed in the positive list of additives for plastic materials
  • Non-greasy dry foods
  • Monitoring negotiations in Mercosur
  • Consultation of positive lists


Question 22 of the document addresses a highly relevant topic for the pursuit of a sustainable future. According to the National Solid Waste Policy (Law 12305/2010), environmentally appropriate final disposal is the last option in the waste disposal hierarchy, after all possibilities of treatment and recovery have been exhausted. Therefore, advancing other forms of disposal such as reuse, recycling, composting, recovery, and energy utilization, or other forms allowed by competent authorities, is necessary.

In this regard, the National Solid Waste Plan (Planares) highlights that actions related to the circular economy are increasingly in focus. These actions represent a shift from the linear economic model, based on extraction, transformation, and disposal, towards a model that prioritizes reduction, reuse, and reintroduction of materials throughout the production chain efficiently, reducing pressure on natural resources, greenhouse gas emissions, waste, reject generation, and pollution.

According to Planares, the recycling rate of plastic waste from packaging was 22.10% in 2018, with PET material representing the highest percentage of recycled plastics (43.3% in 2020).

The Brazilian Chemical Industry Association (Abiquim) emphasizes that mechanical recycling has been performing well in Brazil, but there are obstacles and limitations, such as flexible materials that are difficult to recycle. According to Abiquim, the food and beverage market accounts for almost 30% of the polyolefin market (the most circulated plastic materials worldwide). However, it is a market where post-consumer recycled products have not been able to enter through mechanical recycling.

In this sense, the implementation of chemical recycling is essential to recycle all types of plastic waste, producing in sufficient quantity and quality for complex applications, such as materials in contact with food, and has been a path traced in other regions, such as the United States and the European Union.

Some chemical recycling processes can promote partial depolymerization and obtain oligomers or intermediates. Others can completely depolymerize or degrade the starting materials to obtain monomers with a high degree of purity. Anvisa has received inquiries about the possibility of using these processes in the manufacture of plastic packaging for food.

The updated Questions and Answers document publicizes the response, informing that processes of complete depolymerization that obtain monomers indistinguishable from original monomers, with purity suitable for the manufacture of materials in contact with food and in accordance with applicable regulations for plastic materials, can be used without the need for specific petitioning or authorization. On the other hand, chemical recycling processes that obtain mixtures, oligomers, or intermediates require specific evaluation and must be subject to petitioning.

The possibility of using chemical recycling processes of plastic materials in the manufacture of packaging for food can contribute to achieving the goals of Planares, especially goals 4 and 6:

Goal 4: Reduce the amount of waste and rejects sent for environmentally appropriate final disposal.

Indicator: Recover 48.1% of the total mass of Urban Solid Waste (USW) nationwide by 2040.

Goal 6: Increase the recovery of the dry fraction of USW.

Indicators: Recover 20% of dry recyclables, in relation to the total mass of USW, by 2040. 50% of packaging in general will be recovered through reverse logistics systems by 2040.

According to the Plan, published in 2022, the recovery of recyclable materials is of great importance for diverting solid waste from final disposal units and redirecting them to reuse and recycling processes, with reintegration into one or more production cycles.

To achieve the proposed recycling rates, international references indicate that selective collection is responsible for at least 60% of all recovered mass. According to official databases, the recovery rate of dry recyclables does not exceed 3%. However, considering the projected advances for selective collection, mechanized sorting coupled with conventional collection, and reverse logistics systems, especially for packaging in general, it is estimated that it is possible to achieve 20% recovery of dry recyclables, in relation to the total mass of USW, within a 20-year horizon. Additionally, it is expected to reach the level of 30% of packaging in general recovered through reverse logistics systems, in relation to the total packaging placed on the market, and its progressive increase to reach 50% in 20 years.