# Impact of emerging packaging regulations on international trade and product safety with emphasis on plastic reuse and recycling in Europe and North America

Carinna Saldaña-pierard, Phuong-Mai Nguyen, Frédéric Debeaufort, Olivier

Vitrac, Rafael Auras

► To cite this version:

Carinna Saldaña-pierard, Phuong-Mai Nguyen, Frédéric Debeaufort, Olivier Vitrac, Rafael Auras. Impact of emerging packaging regulations on international trade and product safety with emphasis on plastic reuse and recycling in Europe and North America. Journal of Industrial Ecology, 2025, 29, pp.1473 - 1504. 10.1111/jiec.70079. hal-05340426

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# Impact of emerging packaging regulations on international trade and product safety with emphasis on plastic reuse and recycling in Europe and North America

Carinna Saldaña-Pierard<fnref n="1" />,<fnref n="2" />

Phuong Mai Nguyen<fnref n="3" />

Frédéric Debeaufort<fnref n="4" />,<fnref n="5" />

Olivier Vitrac<fnref n="6" />

Rafael Auras<fnref n="1" /> ID

**Correspondence**

Rafael Auras, School of Packaging, Michigan State University, East Lansing, MI, USA.
Email: aurasraf@msu.edu

**Present address**

Dr. Olivier Vitrac, Founder & Lead Architect, Generative Simulation Initiative, Orsay, France.

Editor Managing Review: Xin Tong

**Funding information**

US Government, Grant/Award Number: SFR63022GR0031-M001; USDA-FAS, Grant/Award Number: TASC-2022-14

**Abstract**

The evolving global landscape of packaging regulations, driven by heightened public concern over single-use packaging and plastic waste, signals a significant shift toward circular economy principles. These regulatory changes, including the United Nations Environmental Programme's endorsement of a legally binding international agreement on plastic waste management, are expected to have far-reaching impacts on product safety, packaging design, and global trade. The newly adopted and emerging policies prioritize waste reduction, reuse, recycling, and the integration of recycled materials. However, the rapid introduction of environmentally driven packaging regulations—especially those targeting sensitive sectors like food and cosmetics—presents potential risks for product/packaging safety and food waste, alongside challenges for trade harmonization across regions with divergent regulatory goals. This forum article reviews key regulatory frameworks from Asia, Europe, and the Americas, detailing material bans, reuse and refill targets, recycling mandates, and extended producer responsibility initiatives. It examines the potential impact of these regulations on global trade dynamics and their implications for universally accepted safety standards. Despite the well-meaning intent behind these laws, gaps in understanding the protective role of packaging and its broader environmental impact may lead to misconceptions in developing sustainable product-packaging systems. Current policies primarily target waste reduction, but an integrated approach is needed – one that considers how packaging extends food shelf life, lowers resource use, and reduces greenhouse gas emissions. Consumer education and transparent communication from regulators and industry will guide informed, sustainable choices, ultimately supporting a more transparent shift toward a circular economy.

**KEYWORDS**

circular economy, environmental regulation, product stewardship, sustainability, trade and environment, waste management

This is an open access article under the terms of the Creative Commons Attribution License, which permits use, distribution and reproduction in any medium, provided the original work is properly cited.

© 2025 The Author(s). *Journal of Industrial Ecology* published by Wiley Periodicals LLC on behalf of International Society for Industrial Ecology.

<footnote n="1">¹School of Packaging, Michigan State University, East Lansing, Michigan, USA</footnote>

<footnote n="2">²Industrial Technology Development Institute, Department of Science and Technology, Bicutan, Taguig, Metro Manila, Philippines</footnote>

<footnote n="3">³Laboratoire National de Métrologie et d'Essais, Trappes, France</footnote>

<footnote n="4">⁴IUT-Dijon_Auxerre-Nevers, Department of BioEngineering, University Burgundy Europe, Dijon, France</footnote>

<footnote n="5">⁵Université Bourgogne Europe, Institut Agro, INRAE, UMR PAM, Dijon, France</footnote>

<footnote n="6">⁶INRAE, AgroParisTech, Université Paris-Saclay, Palaiseau, France</footnote>
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# 1 | INTRODUCTION

Packaging is vital in ensuring the preservation, safe transport, and secure storage of products within the global market. Beyond mere containment, packaging protects items from physical damage, contamination, and degradation, thereby extending their shelf life and maintaining quality. Consequently, for the food sector, this reduces food waste. Packaging design optimized for transportation ensures that goods reach distant markets in optimal condition, enhancing the potential for successful trade relationships and global commerce. The integral role of packaging in the global economy is reflected in the upward trajectory of the packaging market. In 2016, global packaging sales at current prices increased from $845.22 billion to $953.71 billion in 2019, representing an average annual growth rate of 4.1%. The forecast for 2021–2026 remains optimistic, with world packaging sales expected to grow at an average yearly rate of 3.9%, reaching c. $1,230 billion (Platt, 2021).

The modern packaging industry has long relied on a linear “take, make, dispose” model, extracting raw materials, manufacturing products, and discarding them after use (Ellen MacArthur Foundation, 2024; Pearce & Turner, 1989). This approach has caused resource depletion and waste accumulation. To address these issues, the circular economy model, introduced by Pearce and Turner (1989), promotes waste elimination by extending product use through reuse, maintenance, recycling, and composting, preserving resources and reducing waste.

Similar to the Intergovernmental Panel on Climate Change (IPCC) report on climate change, several international reports have highlighted the unsustainability of current solutions, revealing increasingly severe environmental impacts. Plastic use in OECD countries doubled between 2000 and 2019, with municipal solid waste (MSW) increasing nearly twice as much over the same period (OECD, 2022). MSW has surged globally, rising from 2.01 billion tonnes in 2016 to a projected 3.4 billion tonnes by 2050. High-income economies contribute significantly to this increase, generating approximately 1.57 kg of waste per capita per day. In contrast, low-income economies produce only 0.43 kg per capita per day—nearly three times less (Kaza et al., 2016). This trend demonstrates the inefficacy of previous policies. In response to rising societal awareness, governments are accelerating the transition to a circular economy by implementing new regulations and incentives. However, a globally harmonized framework has yet to exist. Circularity concepts are introduced either upstream—encouraging companies to design packaging that reduces material use—or downstream by enhancing reusability, recycling, and incorporating recycled content.

A significant regulatory milestone is the updated European Packaging and Packaging Waste Regulation (PPWR), which imposes stricter standards for packaging used within or imported to Europe. The PPWR has established several waste reduction and sustainability mandates between 2030 and 2050. By 2030, it aims to reduce per capita waste generation by 5%, with further reductions of 10% by 2035 and 15% by 2040 (Article 43). This is supposed to be achieved through measures such as minimizing packaging volume and weight, enhancing packaging reusability—increasing the reusability of transport packaging to 40% by 2030 (Article 29)—and eliminating hazardous substances. Additionally, the regulation sets ambitious recycling targets for 2030, including 55% for plastic, 30% for wood, 80% for ferrous metals, 60% for aluminum, 75% for glass, and 85% for paper and paperboard (Article 52). It also mandates a minimum recycled content in plastic packaging by 2030, requiring 30% for contact-sensitive PET-based packaging, 10% for other materials, 30% for single-use plastic beverage containers, and 35% for other plastic packaging (Article 7). Furthermore, eliminating hazardous substances, such as per- and polyfluoroalkyl substances (PFAS), and improving labeling practices support these efforts by enhancing transparency and compliance (European Parliament, 2024). It also strengthens extended producer responsibility (EPR) schemes to ensure producers are accountable for their packaging throughout its life cycle. However, consumers and the industry are also interested in industrial and home compostable packaging, as evidenced by the extensive literature regarding biodegradable and sustainable polymers (Barone et al., 2025; Mohanty et al., 2022). The European Parliament pushed for the harmonization of compostable packaging standards for 2026 (European Parliament, 2024). This forum article will not extensively cover biodegradable and compostable polymers.

Other regions are also advancing regulations to address plastic waste. In Canada, the proposed measures target plastic waste management through mandates for minimum recycled content, recyclable and compostable labeling, and a goal for all packaging to be 100% reusable, recyclable, or compostable by 2028 (Environment & Climate Change Canada, 2023b). The United Nations Environment Programme (UNEP) has endorsed resolutions for a legally binding global plastics agreement, proposing mandates on recycled content, packaging minimization, recyclability, reusability, and harmful substance restrictions (United Nations Environment Programme, 2023).

With all 193 UN member states involved, this treaty could significantly expand global packaging regulations, advancing Sustainable Development Goals (SDGs) 2, 3, 6, 7, 12, 13, 14, and 15 of the 2030 Agenda. The first session of the fifth Intergovernmental Negotiating Committee (INC-5.1) was held in Busan, Republic of Korea, with the second session (INC-5.2) set for August 2025 in Geneva, Switzerland.

These regulatory shifts introduce significant complexity for supply chains, especially where stringent safety and traceability are paramount, as in food and medical packaging. Packaging that meets these safety standards must also comply with sustainability mandates—posing both technical and logistical challenges. Moreover, the globalized nature of trade means that regional discrepancies in regulation can act as trade barriers, increasing compliance costs and fragmenting markets.

The possible benefits of regulatory convergence, particularly for food-contact materials (FCM), are discussed in a recent International Life Sciences Institute (ILSI) Task Force review (Nerin et al., 2025). Key directions include: (i) harmonizing risk assessment methodologies to enhance consistency and transparency; (ii) refining scientific tools for exposure and toxicity estimation; and (iii) aligning regulatory frameworks to facilitate international trade and bolster consumer confidence in material safety. Crucially, as the demand for recycled materials increases across sectors,
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<caption>**FIGURE 1** Examples of existing and emerging regulatory developments regarding packaging worldwide are indicated as (1) packaging prohibitions, (2) recyclability requirements, (3) recycled content requirements, (4) EPR requirements, (5) reuse and refill requirements, and (6) packaging minimization requirements.</caption>

including food, cosmetics, household, and industrial packaging, there is mounting competition for high-quality recycled streams. This creates new pressures: ensuring safety in sensitive applications while balancing material availability, economic incentives, and diverging regulatory acceptance. Recycled inputs may originate from diverse sources with inconsistent traceability, challenging the alignment of safety and circularity goals across product classes.

This paper provides a comparative overview of emerging and existing legal packaging requirements across selected regions in the Americas, Asia, and Europe. It explores anticipated regulatory developments, primarily in food packaging, with specific attention to overlapping demands from cosmetic applications. It examines the potential impact of these new policies for international trade and product safety standards, particularly in light of reuse and recycling mandates. Particular attention is given to the North American and European regulatory developments, which increasingly shape global expectations.

## 2 | OVERVIEW OF CURRENT AND EMERGING PACKAGING WASTE LEGISLATION

Regulations are essential in guiding the adoption of sustainable packaging practices, as they set guidelines and standards that businesses must adhere to. These frameworks ensure accountability and offer incentives for responsible packaging practices. However, the regulatory landscape varies considerably across global regions and even more so at the level of individual countries or states (see Figure 1). The regulatory measures commonly fall into the following categories:

a. **Packaging prohibitions:** These measures include bans on specific packaging types, such as polystyrene (PS) containers, various single-use packaging formats, and polyvinyl chloride (PVC) containers, largely due to their challenges in recycling. Additionally, they encompass bans on packaging with intentionally added substances (IAS) of concern (e.g., PFAS and bisphenol A [BPA]), and restrictions on concentration levels of certain hazardous compounds (e.g., lead, cadmium, and mercury) in packaging materials (CA AB1200, 2021; European Parliament, 2024; ME LD1503, 2021).

b. **Promotion of reuse and refill strategies:** Numerous countries are advancing measures to increase the proportion of reusable packaging in the market and establish systems for its environmentally sound reuse. These strategies include deposit-return schemes and setting quantitative targets for a minimum share of reusable packaging for various packaging streams (Environment & Climate Change Canada, 2023b; Oregon Department of Environmental Quality, 2007; WA SB5323, 2020).
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c. Emphasis on achieving recyclability and increased recycling: Many nations are intensifying efforts to improve the recyclability of packaging materials and boost overall recycling rates. Measures in this category often involve establishing standardized specifications for packaging material structures to facilitate easier recycling (Blank & Gregor, 2024; Song & Park, 2024; Steinhorst & Beyerl, 2021).

d. *Requiring packaging to have minimum recycled content:* In certain countries, regulations mandate a minimum percentage of recycled material in packaging. These requirements aim to stimulate demand for a robust and safe post-consumer recycled (PCR) market suitable for the intended uses, such as food, cosmetic, medical, and pharmaceutical contact, thereby reducing reliance on virgin materials and diverting waste from landfills (European Parliament, 2024; C. CA AB793, 2020; Lee et al., 2024).

e. EPR programs: EPR legislation is expanding across multiple regions and gaining momentum (Enders et al., 2024; WA SB5154, 2024). These initiatives hold producers accountable for the end-of-life (EoL) management of their packaging, encouraging responsible recycling and disposal practices (Lorang et al., 2022).

Table 1 provides an overview of some regulatory measures on packaging across selected countries/states, categorized into six critical regulatory trends. The main targets and differences between regulations, countries, and strategies are summed up hereafter.

In the United States, bans focus on PFAS, hard-to-recycle plastics like expanded polystyrene (EPS) and PVC, and single-use bags. Similar bag restrictions exist in Latin America, Europe, and Asia countries. Canada targets rigid foams, while the EU bans PFAS, EPS, and sets limits on heavy metals under the PPWR.

Recycling targets vary, with early claims in Chile (2016), Germany (2020), and Brazil and India (2022), and broader targets set for 2030 in the EU and China. PCR content mandates are growing, especially for plastic bottles and bags, led by US states like California and New Jersey, the EU's PPWR (up to 65% by 2040 in selected categories), and mandates in India, South Korea, and Chile.

Reuse/refill policies are emerging globally. US states focus on reusable bags and consumer-supplied containers, while the EU requires 10% reusable packaging by 2030. Latin American and Asian countries also promote reuse, with India and China implementing measurable targets.

EPR laws are expanding, with US states, the EU, and countries like Chile and Brazil requiring producers to finance food packaging waste management through Producer Responsibility Organizations (PROs). Asia shows mixed progress, with Japan, South Korea, and India enforcing EPR schemes, but not specifically focused on food and cosmetic packaging materials.

Other requirements include bans on misleading recyclability labels (e.g., California), single-use plastics (SUP) reduction mandates (France and EU), and eco-design rules (Japan and India). Packaging regulations are trending toward more stringent, harmonized, and sustainability-focused approaches.

Figure 2 shows an analysis based on the structured dataset provided in Table 1, which compiles 14 binary variables describing key packaging-related regulatory features across 21 entities (countries and selected US states). These features include recycling targets, PCR content mandates, reuse or refill obligations, EPR schemes, and bans or restrictions on substances (e.g., PFAS) and packaging formats (e.g., EPS, oxo-degradable materials, oversized boxes, or fruit and vegetable packaging). (1) **Regulatory complexity:** For each entity, we computed a complexity score as the number of active features (nonzero values) in Table 1. This score was used to determine the area of circles in panel (a), highlighting variation in regulatory density across regions. (2) **Similarity and clustering:** To compare the regulatory profiles across jurisdictions, we computed pairwise similarities using the Jaccard distance, a standard metric for binary data that quantifies how many regulatory features two entities share relative to the total number of features present in either. A pairwise Jaccard distance matrix was calculated using the binary feature profiles. We applied hierarchical clustering (average linkage) to group entities into **five clusters** consistently shown in color across all panels. (3) **Principal coordinates analysis (PCoA):** We performed a PCoA on the Jaccard distance matrix using eigendecomposition of the double-centered distance matrix. The two dominant axes, explaining 71.4% and 31.0% of the total variance, respectively, are shown in panel (b). The centroid of each cluster was used to annotate the clusters and as input to panel (c). (4) **Cluster dendrogram:** A second-level hierarchical clustering was performed on the cluster centroids in the PCoA space to reveal similarity patterns between entire clusters (panel c). Cluster labels in this dendrogram include the list of constituent entities, corresponding to those shown in Table 1.

The comparative analysis of regulatory features (Table 1) reveals an emerging global convergence in packaging regulations, particularly along four major regional blocks: North America, South America, Europe, and Asia. This convergence is visibly structured in Cluster 1, which groups together most entities with advanced and comprehensive regulations, including EU countries, coastal US states (e.g., California, Oregon, and Maine), and several South American (e.g., Brazil and Chile) and Asian countries (e.g., Japan, South Korea, and India). These jurisdictions share high regulatory complexity, characterized by coordinated mandates on recycling targets, PCR content, reuse systems, and EPR schemes.

Europe, spearheaded by the EU-wide PPWR initiative, appears as the primary impulse vector driving this regulatory harmonization. The PCoA plot (Figure 2b) shows that the majority of high-complexity entities coalesce in a compact region of the similarity space, forming a core around Cluster 1. This indicates not only shared practices but also likely mutual influence and regulatory diffusion.

Coastal US states and South American countries appear to be early followers, showing significant alignment in policy scope with European standards. Meanwhile, Asian countries are more heterogeneous and lagging slightly in adopting some regulatory pillars (e.g., EPR implementation or reuse systems), although they show a clear trajectory toward convergence, as reflected in their proximity to Cluster 1 in both PCoA and dendrogram projections.
<table><caption>TABLE 1 Selective cross-country comparison of legislation addressing packaging waste.</caption><thead><tr><th>Country/state</th><th>Packaging prohibitions</th><th>Recycling targets</th><th>PCR requirements</th><th>Reuse/refill mandate</th><th>EPR obligations</th><th>Other requirements</th></tr></thead><tbody><tr><td>North America</td><td>United States (US)/California</td><td>California Assembly Bill 1200, enacted in 2021, bans the distribution or sale of any food packaging that contains regulated PFAS in the state of California (CA AB1200, 2021). California Senate Bill 270, enacted in 2014, prohibits stores from providing single-use carryout bags, and recycled paper bags or compostable bags unless made available for purchase for not less than $0.10 (CA SB270, 2014).</td><td>California Senate Bill 54, enacted in 2022, requires that by 2032 all single-use packaging/plastic food service ware be recycled after use. To work up to the 2032 targets, 30% of packaging needs to be recycled by January 1, 2028, and 40% by 2030 (Solid Waste, 2022).</td><td>California Assembly Bill 793, enacted in 2020, requires plastic beverage containers to contain no less than 15% PCR by January 2022: 25% by January 2025, and 50% by January 2030 (CA AB793, 2020). California Senate Bill 270 (2014) mandates that standard recycled paper bags contain at least 40% post-consumer recycled (PCR) material, or 20% PCR for bags carrying eight pounds or less. It also requires reusable plastic grocery bags to have a minimum of 40% PCR material and to be recyclable in the state (CA SB270, 2014).</td><td>California Senate Bill 270 (2014) only allows the use of reusable bags from certified producers of reusable grocery bags. These reusable bags should be reusable at least 125 times, capacity of at least 15 be cleanable, be labeled, not contain toxic materials, and if recyclable, comply with recycling guidelines (CA SB270, 2014).</td><td>California SB 54 (2022) directs producers to create a Producer Responsibility Organization (PRO), and to design, fund, and operate a statewide program that properly collects and recycles, or composts discarded products (Solid Waste, 2022).</td></tr><tr><td>US/Colorado</td><td>Colorado House Bill 1162, passed in 2021, prohibits stores and retail food establishments from providing single-use carryout bags and expanded polystyrene (EPS) cups and containers to customers 2021.</td><td>The Colorado Solid and Hazardous Waste Commission adopted a statewide goal for municipal solid waste diversion of 35% by 2026 goal for municipal solid waste diversion of 35% by 2026, and 45% by 2036 (State of Colorado, 2024). No specific statewide packaging recycling targets were identified.</td><td>No specific PCR requirements for packaging were identified.</td><td>No specific reuse/refill mandate for packaging were identified.</td><td>Colorado House Bill 1355, passed in 2022, requires the appointment of a non-profit organization to implement and manage a statewide recycling program, funded by producers of products that use packaging materials and paper products (CO HB1355, 2022).</td></tr></tbody></table>

(Continues)
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<table><caption>TABLE 1 (Continued)</caption><thead><tr><th>Country/state</th><th>Packaging prohibitions</th><th>Recycling targets</th><th>PCR requirements</th><th>Reuse/refill mandate</th><th>EPR obligations</th><th>Other requirements</th></tr></thead><tbody><tr><td></td><td>Connecticut House Bill 7424, passed US/Connecticut in 2019, banned the provision and sale of single-use plastic bags with thickness of less than 4 mils to customers at the point of sale 2019, Connecticut Senate Bill 837, passed in 2021, prohibits the sale of food package to which PFAS has been intentionally added (CT SB837, 2021).</td><td>Connecticut's 2016 Comprehensive Materials Management Strategy (CMMS) targeted a 60% diversion of materials from disposal by 2024 (Connecticut Department of Energy & Environmental Protection, 2023). No statewide packaging recycling targets were identified.</td><td>Connecticut House Bill 6664, passed in 2023, requires plastic beverage containers to have 25% PCR content by 2027, and 30% by 2032 (CT HB6664, 2023).</td><td>No specific reuse/refill mandate for packaging were identified.</td><td>Connecticut House Bill 6664, passed in 2023, creates a registration program for producers of plastic beverage containers beginning April 2026 (CT HB6664, 2023).</td><td></td></tr><tr><td>US/Illinois</td><td>Illinois in January 12, 2024 proposed House Bill 4448, which prohibits any store or food service business from providing single-use plastic carryout bags to customers (IL HB4448, 2024).<br/>Illinois House Bill 3865, proposed on February 17, 2023, prohibits the sale and distribution of polystyrene foam food service containers (IL HB3865, 2023).<br/>Illinois Senate Bill 88, proposed on January 20, 2023, prohibits the sale and distribution for use of food packaging containing intentionally added PFAS (IL SB88, 2023).</td><td>The Illinois Solid Waste Planning and Recycling Act aims to recycle 25% of all waste generated for each county (Illinois Environmental Council, n.d.). No statewide packaging recycling targets were identified.</td><td>Illinois SB1555 (Packaging and Paper Products Stewardship Act), passed in 2023, requires each producer to achieve a PCR content of 15% by 2028, 25% by 2031, and 50% by 2034 in the rigid plastics it produces (IL SB1555, 2023).</td><td>Illinois SB 1555 requires producer or producer responsibility organizations acting on the producer's behalf to propose reuse and recycling rates, and a description of how they will meet or exceed these targets (IL SB1555, 2023).</td><td>Illinois SB1555 requires that by July 1, 2026, no producer shall sell or distribute unless the producer or producer responsibility organization acting on the producer's behalf, has a 5-year program plan approved by the Illinois Environmental Protection Agency for meeting the requirements of the Act (IL SB1555, 2023).</td><td></td></tr><tr><td>US/Maine</td><td>Maine House Bill 289, passed in 2019, prohibits the distribution of disposable food service containers composed in whole or in part of polystyrene foam (ME LD289, 2019).<br/>Maine House Bill 1503, passed in 2021, prohibits the sale and distribution of any product that contains intentionally added PFAS (ME LD1503, 2021).</td><td>Maine's goal is to recycle or compost 50% of the municipal solid waste tonnage generated each year within the state (Title 38, §2132, n.d.).</td><td>Maine LD1467, passed in 2022, requires that starting January 2026, manufacturers of plastic beverage containers should ensure that containers sold in the state have at least 25% PCR content; and 30% by January 2031 (ME LD1467, 2022).</td><td>Maine LD2091, passed in 2024, allows consumers to supply their own containers to purchase food, beverage, and non-food items. It also allows business owners to sell their products in returnable, reusable, or refillable containers/ packaging (ME LD2091, 2024).</td><td>Maine LD1541, passed on July 2, 2021, establishes a stewardship program in the state, where producers are expected to pay fees that are intended to incentivize recyclability of packaging material, use of recycled content, reduction in the amount of packaging material, and lower toxicity (ME LD1541, 2021).</td><td></td></tr></tbody></table>

(Continues)
<table><caption>TABLE 1 (Continued)</caption><thead><tr><th>Country/state</th><th>Packaging prohibitions</th><th>Recycling targets</th><th>PCR requirements</th><th>Reuse/refill mandate</th><th>EPR obligations</th><th>Other requirements</th></tr></thead><tbody><tr><td>US/New Jersey</td><td>New Jersey Senate Bill 864, passed in 2020, prohibits the provision or sale of single-use plastic carryout bags, single-use paper carryout bags, and polystyrene foam food service products (NJ SB864, 2020).<br/>New Jersey Senate Bill 1042, proposed in January 9, 2024, prohibits the sale and distribution of any food packaging that contains intentionally added PFAS (NJ SB1042, 2024).<br/>New Jersey Senate Bill 226, also introduced on January 9, 2024, prohibits the use of a shipping box greater than two times the volume of the product being shipped (NJ SB226, 2024).</td><td>New Jersey's goal is to recycle 50% of the municipal solid waste stream and 60% of the overall waste stream by the end of 1995 (New Jersey Department of Environmental Protection, 2017).</td><td>New Jersey Senate Bill 2515, passed in 2022, requires a minimum PCR content of 15% with 5% increases every 3 years up to 50% for beverage containers; 10% for all other rigid containers with 10% increases every 3 years up to 50%; 20% for plastic carryout bags and trash bags by 2024, and 40% by 2027; and 35% for glass containers by January 2024 (NJ SB2515, 2022).<br/>New Jersey Assembly Bill 4367, proposed in 2024, prohibits the sale or distribution of cardboard packaging with less than 75% PCR content (NJ A4367, 2024).</td><td>No specific reuse/refill mandate for packaging was identified.</td><td>No specific EPR law for packaging was identified.</td><td>Proposed New Jersey AB4367 requires producers of plastic packaging to reduce the amount, by weight, of their packaging sold annually (NJ A4367, 2024).</td></tr><tr><td>US/Oregon</td><td>Oregon's Senate Bill 543, passed in 2023, prohibits vendors from using PS containers in sales of prepared food, selling and distribution of PS foam packaging peanuts, as well as selling and distribution of containers with PFAS (OR SB543, 2023).</td><td>Oregon sets a statewide recovery goal of 25% for plastic waste (Oregon Department of Environmental Quality, n.d.).</td><td>Oregon requires rigid plastic containers to contain 25% PCR plastic content or reused or refilled at least five times (Oregon Department of Environmental Quality, 2007).<br/>Oregon requires glass containers to contain 50% recycled content (Oregon Legislature, 2023).</td><td>Oregon requires rigid plastic containers to contain 25% PCR plastic content or reused or refilled at least five times (Oregon Department of Environmental Quality, 2007).</td><td>Oregon's Senate Bill 582, passed in 2021, creates a producer responsibility program that requires producers of packaging to join and pay annual fees into a PRO (OR SB582, 2021).</td><td></td></tr></tbody></table>

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<table><caption>TABLE 1 (Continued)</caption><thead><tr><th>Country/state</th><th>Packaging prohibitions</th><th>Recycling targets</th><th>PCR requirements</th><th>Reuse/refill mandate</th><th>EPR obligations</th><th>Other requirements</th></tr></thead><tbody><tr><td rowspan="3">Canada</td><td>Washington Senate Bill 5323, passed US/Washington in 2020, prohibits use of single-use plastic/paper carryout bag or reusable bag made that does not meet PCR content requirements (WA SB5323, 2020).</td><td>No specific recycling target for packaging was identified.</td><td>Washington SB5323 requires paper bags to contain 10% PCR and capable of composting as per ASTM56868. Reusable plastic bags are required to have 20% PCR content by 2022, and 40% thereafter (WA SB5323, 2020).</td><td>Washington SB5323 requires reusable bags to have a minimum lifetime of 125 uses with capacity to carry a minimum of 22 pounds over a distance of 175 ft (WA SB5323, 2020).</td><td>Washington Senate Bill 5154, introduced on January 8, 2024, requires producers of packaging to join a producer responsibility organization, which by June 30, 2025, will have to submit an annual payment to fund the cost of packaging waste management (WA SB5154, 2024).</td><td></td></tr><tr><td>Washington Senate Bill 5022, passed in 2021, prohibits the sale and distribution of EPS packing peanuts and EPS containers (WA SB5022, 2021).</td><td></td><td>Washington SB5022 requires plastic beverage containers to have 15% PCR by 2023, 25% by 2026, 50% by 2031; plastic containers for household cleaning and personal care 15% by 2025, 25% by 2028, and 50% by 2031 (WA SB5022, 2021).</td><td></td><td></td><td></td></tr><tr><td>(Proposed) Fresh fruits and vegetables will be required to be distributed/sold in bulk and/or plastic-free packaging (Environment & Climate Change Canada, 2023b). Ban on manufacturing, use, and import of rigid foam plastic produced through use of CFCs or HCFCs (Ozone-depleting Substances and Halocarbon Alternatives Regulations 2016/137) (United Nations Environment Programme, 2018).</td><td>(Proposed) Requires all primary food plastic packaging to be 100% recyclable by 2028 (Environment and Climate Change Canada, 2023b).</td><td>Minimum recycled content mandate, but not for food-contact material (Environment and Climate Change Canada, 2023b).</td><td>(Proposed) Requires all primary food plastic packaging to be 100% reusable by 2028 (Environment and Climate Change Canada, 2023b).</td><td>(Proposed) Federal Plastics Registry: Brands must report type and tonnage of plastic packaging sold in Canada (Government of Canada, 2023).</td><td></td></tr></tbody></table>

(Continues)
<table><caption>TABLE 1 (Continued)</caption><thead><tr><th>Country/state</th><th>Packaging prohibitions</th><th>Recycling targets</th><th>PCR requirements</th><th>Reuse/refill mandate</th><th>EPR obligations</th><th>Other requirements</th></tr></thead><tbody><tr><td>Argentina</td><td>The City of Buenos Aires prohibits the use of plastic bags in supermarkets and hypermarkets (Xanthos &amp; Walker, 2017).</td><td>The City of Buenos Aires enforced Law No. 1854/2005 which promotes product recycling and sorting of products that can be recycled (US Department of Agriculture—Foreign Agricultural Service, 2023a).</td><td>The City of Buenos Aires enforced Law No. 1854/2005 which specifies that products produced using recycled or reused inputs must be prioritized by organizations within the city (US Department of Agriculture—Foreign Agricultural Service, 2023a).</td><td>The City of Buenos Aires enforced Law No. 1854/2005 which promotes the reduction of waste and use of long-lasting or reusable products, and measures toward the gradual replacement of disposable for reusable packaging (US Department of Agriculture—Foreign Agricultural Service, 2023a).</td><td>The City of Buenos Aires enforced Law No. 1854/2005 which obligates producer, importer, distributor, agent, or any person placing a product in the market to take charge of the waste management derived from his/her products, or participate in an organized system of waste management, or contribute to a public waste management system (US Department of Agriculture—Foreign Agricultural Service, 2023a).</td><td></td></tr><tr><td>Brazil</td><td>Bill No. 2726/2023 was proposed in 2023, which will establish a national policy for the control of PFAS (Koll et al., 2024).</td><td>Decree No. 11.043, enacted in April 2022, establishes targets to boost recycling rates across Brazil by 14% by 2024, and 48% by 2040 (International Trade Administration, 2023). No specific recycling target for packaging was identified.</td><td>A draft decree is underway that will set recycled content requirements for plastic packaging in Brazil (Institute for Global Environmental Strategies, 2024a).</td><td>Law, 12.305/2010 encourages the reuse of packaging materials; however, it does not specify detailed requirements for their reuse (Law No. 12305, 2010).</td><td>In 2015, the Brazilian government entered into a reverse logistics agreement with a coalition of packaging companies (Langhill, 2021; Rutkowski, 2021). This agreement mandates producers to invest in waste management cooperatives, establish collection points through contracts with retailers and management systems, and educate consumers on the proper ways to return packaging for recycling (Langhill, 2021). This initiative aims to gradually reduce the amount of packaging waste sent to landfills by 22% by 2018, and by 45% by 2031 (Rutkowski, 2021).</td><td></td></tr></tbody></table>

(Continues)
<figure><img src="image_7.png" /></figure>

<table><caption>TABLE 1 (Continued)</caption><thead><tr><th>Country/state</th><th>Packaging prohibitions</th><th>Recycling targets</th><th>PCR requirements</th><th>Reuse/refill mandate</th><th>EPR obligations</th><th>Other requirements</th></tr></thead><tbody><tr><td rowspan="2">Chile</td><td rowspan="2">Law No. 21.100, passed in 2018, prohibits establishments from providing plastic shopping bags. Plastic bags for packaging food are, however, exempted from this prohibition (Ley Núm. 21.100, 2018).</td><td rowspan="2">Law No. 20.920, passed in 2016, sets a target of 30% recycled waste (Ley Núm. 20.920, 2016; US Department of Commerce Administration, 2023).</td><td rowspan="2">Law No. 21.368, passed in 2021, requires 15% minimum recycled content of Chilean origin in plastic bottles by 2025, 25% by 2030, 50% by 2040, 60% by 2050, and 70% by 2060 (US Department of Agriculture—Foreign Agricultural Service, 2021).</td><td rowspan="2">Law No. 21.368, published in 2021, limits the distribution of non-reusable single-use food packaging trays by food establishments. The law also requires beverage retailers to make consumers aware of the importance of returnable bottles, and their obligation to offer them for sale (Lührmann, 2023).</td><td rowspan="2">Law No. 20.920, passed in 2016, established "polluter pays" principle, and required all waste generators to organize and finance the waste management of priority products, which includes packaging (Ley Núm. 20.920, 2016).</td><td rowspan="2"></td></tr><tr><td></td><td></td></tr><tr><td colspan="7"><strong>Europe</strong></td></tr><tr><td rowspan="2">France</td><td rowspan="2">Ban on all single-use plastic packaging for fresh fruit and vegetables by 2026 and ban on the use of PLU stickers on fresh fruits and vegetables unless home compostable.<br>Ban plastic containers for infant and toddlers.<br>Ban all single-use plastics by 2040.</td><td rowspan="2">100% of SUP recycled by 2025 (AGEC law) and 90% of plastics must be collected for recycling.</td><td rowspan="2">The AGEC law imposes a minimum incorporation rate of recycled plastic in beverage bottles of at least 30% for all plastic bottles by 2030.</td><td rowspan="2">Requires that 10% of all food and non-food packaging be reusable/refillable instead of recyclable by 2027.</td><td rowspan="2">Articles L541-1 to L541-50 of the AGEC Law and 3R decree Code de l'Environnement, dealing with the EPR obligations & Law 2023-305 of the 24th April 2023 on the extension & fusion of all packaging producer sectors (Titre IV: Déchets (Articles L541-1 à L542-14), 2024; LOI N° 2023-305, 2023).</td><td rowspan="2"></td></tr><tr><td></td><td></td></tr><tr><td rowspan="2">Spain</td><td rowspan="2">Royal Decree 1055/2022 requires whole fresh fruits and vegetables to be sold loose, except for fruits and vegetables that are sold in multipacks weighing 1.5 kg or more, registered varieties, those produced using ecological agriculture methods, or those at risk of deterioration if sold loose (KPMG Abogados, 2023).</td><td rowspan="2">Royal Decree 1055/2022 targets to reduce by 13% the weight of packaging waste generated with respect to that generated in 2010 by 2025; and 15% for 2030 (KPMG Abogados, 2023).</td><td rowspan="2">Law 7/2022 (Plastic Tax Law), which took effect January 2023, stipulates that recycled plastic is exempt from taxation, provided that companies possess a certificate from an official certifying that the packaging was recycled. However, the term "ecycled plastic" is not clearly defined, leaving it unclear whether packaging must be 100% recycled plastic or if a lower percentage is permissible (Ferriz, 2023).</td><td rowspan="2">Royal Decree 1055/2022 requires food retail outlets with floor area exceeding 400 m² to designate at least 20% of their sales area to products presented without primary packaging or in reusable packaging. For food outlets exceeding 300 m², retailers are obligated to inform consumers to return reusable packaging and to dispose of it separately in relevant containers; promote reusable bags and optimize the use of single-use bags, as well as the availability of reusable packaging in retail outlets (KPMG Abogados, 2023).</td><td rowspan="2">Royal Decree 1055/2022 obligates producers to finance and organize the management of their waste through an Extended Producer Responsibility System (EPRS) (KPMG Abogados, 2023). Law 7/2022, which was entered into force in January 2023, imposes a special tax on non-reusable plastic packaging, which amounts to 45-euro cents per kilo of non-recycled plastic (US Department of Agriculture—Foreign Agricultural Service, 2023c).</td></tr><tr><td></td><td></td></tr></tbody></table>

(Continues)
<table><caption>TABLE 1 (Continued)</caption><thead><tr><th>Country/state</th><th>Packaging prohibitions</th><th>Recycling targets</th><th>PCR requirements</th><th>Reuse/refill mandate</th><th>EPR obligations</th><th>Other requirements</th></tr></thead><tbody><tr><td>Germany</td><td>German Ordinance on Single-Use Plastics (Einwegkunststoffverbotsvorordnung), implementing the requirements of Directive (EU) 2019/904, prohibits to-go food containers and beverage containers/cups made from EPS (Steinhorst & Beyerl, 2021). The same ordinance also prohibits use of oxo-degradable plastics, and single-use plastic beverage containers can only be placed on the market if their plastic closures and lids remain attached to the containers during use (Blank & Gregor, 2024).<br>The German Packaging Act prohibits light plastic carrier bags with wall thickness between 15 and 50 micrometers, designed and intended to be filled at the point of sale (Blank & Gregor, 2024).</td><td>The recycling targets under the German Packaging Act are set at 90% for glass, paper, cartons, cardboard, ferrous metals, aluminum, and plastics; 80% for beverage cartons; 70% for composites; and 63% for mechanically recycled plastics (Bünemann et al., 2020).</td><td>The German Packaging Act requires PET beverage bottles to contain at least 25% recycled plastic by 2025, and 30% by 2030, with the latter applying to all single-use plastic bottles (Blank & Gregor, 2024; Steinhorst & Beyerl, 2021).</td><td>The German Packaging Act mandates that restaurants, bistros and cafes offering takeout food or drinks must owners and online retailers, are provide reusable packaging at no higher cost than disposable food packaging (Blank & Gregor, 2024).<br>Under the German Packaging Act, transport packaging from manufacturers and retail must also be taken back for reuse or consigned to recovery (BMUV, 2023).</td><td>Anyone who produces or distributes packaging filled with goods, including small business obliged to pay and enter into a system participation agreement with recovery and recycling services in Germany. The companies under legal obligation are also required to register with the Central Agency Packaging Register-ZSVR (Stiftung Zentrale Stelle Verpackungsregister, 2023).<br>The Single-Use Plastics Fund Act (EWKFondsG), enacted in January 2024, requires manufacturers to cover the costs of their single-use plastics collected as public waste. They must pay a levy calculated by multiplying the mass of their reported single-use plastic products by the levy rate specified in the Single-Use Plastics Ordinance (Enders et al., 2024).</td><td></td></tr></tbody></table>

(Continues)
<table><caption>TABLE 1 (Continued)</caption><thead><tr><th>Country/state</th><th>Packaging prohibitions</th><th>Recycling targets</th><th>PCR requirements</th><th>Reuse/refill mandate</th><th>EPR obligations</th><th>Other requirements</th></tr></thead><tbody><tr><td>EU wide</td><td>The PPWR prohibits the use of several single-use packaging formats and food packaging containing intentionally added PFAS. It also proposes new maximum allowable limits for lead, cadmium, mercury, and hexavalent chromium in packaging, and prohibits "unnecessary" packaging layers (e.g., double walls and false bottoms), and emphasizes that weight, volume, and empty space ratio for packaging be reduced to a minimum (European Parliament, 2024).<br><u>Directive (EU) 2019/904</u> restricts the placing on the market of food containers and beverage containers made of EPS, and products made from oxo-degradable plastics (Single-Use Plastics Directive, 2019).</td><td>The PPWR requires all packaging to be recyclable, that is, designed for recycling by January 2030 and recycled at scale by January 2035 (European Parliament, 2024).<br><u>Recycling target</u> of 65% by weight for all packaging waste generated by December 31, 2025, and 70% by December 31, 2030 (European Parliament, 2024).</td><td>The PPWR requires that contact-sensitive packaging (except beverage bottles) made from PET plastic as major component must contain 30% PCR content by January 2030, and 50% by 2040; For contact-sensitive packaging made from plastic materials other than PET, 10% PCR content by January 2030, and 25% by January 2040; For single-use plastic beverage bottles, 30% PCR by January 2030, and 65% by January 2040; For other plastic packaging, 35% PCR by January 2030, and 65% by January 2040 (European Parliament, 2024).</td><td>The PPWR requires member states to establish a register that shall serve to monitor compliance of producers of packaging. It also prohibits producers that are not registered from making their packaging available on the market (European Parliament, 2024).</td><td>The PPWR introduces a wide range of targets on reuse and refill, and requires a system for reuse of reusable packaging to be in place. It also requires companies to ensure that 20% of beverages filled into a container at the point of sale for take away are in reusable packaging within a system for reuse or by enabling refill by January 2030, and 80% by January 2040 (European Parliament, 2024).</td><td>The PPWR requires minimizing the weight and volume of packaging and avoiding unnecessary packaging.<br>The PPWR imposes several label requirements to include information on material composition, harmonized label for packaging subject to deposit refund systems or schemes (DRS), and label on packaging reusability (European Parliament, 2024).<br>It also requires sticky labels for fruit and vegetables, filter coffee pods, and lightweight carrier bags to be compostable, as well as requires packaging to be designed to minimize its weight and volume, and empty space ratio (European Parliament, 2024).</td></tr><tr><td>Asia</td><td>China</td><td>Target: Increase the recycling rate from 34% to 70% by 2030 (Packaging Europe, 2024). No specific recycling target for packaging was identified.</td><td>"Urgent Notice on the Special Rectification of Plastic Packaging Containers for Food" (2006): Recycled plastic production and processing enterprises are prohibited from selling recycled plastic to food packaging container production enterprises (Xiaowei, 2023).</td><td>"Action Plan for Advancing the Green Transformation of Express Packaging" came into effect on November 23, 2023. The action plan calls for 10% of intracity deliveries to use "recyclable express packaging" (boxes that can be reused multiple times for their original purpose), and aims to expand the reuse of old cardboard boxes (Sino-German Environmental Partnership, 2024).</td><td>Current laws and regulations on producer responsibility schemes primarily focus on electrical, electronics, automotive, and battery products. There is no relevant legislation addressing producer responsibility schemes for packaging (Lichtenstein, 2023).</td><td></td></tr></tbody></table>

(Continues)

<figure><img src="image_8.png" /></figure>
<table><caption>TABLE 1 (Continued)</caption><thead><tr><th>Country/state</th><th>Packaging prohibitions</th><th>Recycling targets</th><th>PCR requirements</th><th>Reuse/refill mandate</th><th>EPR obligations</th><th>Other requirements</th></tr></thead><tbody><tr><td>India</td><td>Plastic Waste Management Rules, 2016 require carry bags and plastic packaging to be either in natural shade without added pigments or made using only pigments and colorings which are in conformity with Indian Standard IS 9833:1981. It also requires plastic packaging to have a thickness not less than 50 microns. Under the same rules, manufacture and use of non-recyclable multilayered plastic is prohibited (Ministry of Environment & Forests, 2016). Plastic Waste Management (Amendment) Rules, 2021 prohibit the sale and use of single-use polystyrene and expanded polystyrene plastics effective July 1, 2022 (Ministry of Environment, Forest & Climate Change, 2021).</td><td>Plastic Waste Management (Amendment) Rules, 2022 requires Producers, Importers, and Brand Owners (PIBOs) of rigid plastic packaging (Category I) and compostable plastic packaging (Category IV) to recycle 50% of their EPR target by 2024, 60% by 2025, 70% by 2026, and 80% by 2027. For flexible plastic packaging (Category II) and multilayer plastic packaging (Category III), 30% of PIBOs EPR target must be recycled by 2024, 40% by 2025, 50% by 2026, and 60% by 2027 (Ministry of Environment, Forest & Climate Change, 2022).</td><td>Plastic Waste Management (Amendment) Rules, 2022 requires Producers of Category I packaging to incorporate 30% recycled content by 2025, 40% by 2026, 50% by 2027, and 60% by 2028 and onward. For Category II packaging, 10% recycled content is required by 2025, and 20% by 2027. For Category III packaging, 5% is required by 2025, and 10% by 2027 and onward (Ministry of Environment, Forest, and Climate Change, 2022).</td><td>Plastic Waste Management (Amendment) Rules, 2022 requires Brand Owners of rigid plastic packaging, with weights less than 4.9 L or kg, to reuse 10% of produced packaging by 2025, 15% by 2026, 20% by 2027, and 25% by 2028 and onward. For rigid plastic packaging, with weights more than 4.9 L, brand owners are required to reuse 70% of the produced packaging by 2025, 75% by 2026, 80% by 2027, and 85% by 2028 and onward. For food-contact applications, the packaging shall comply with the regulations set by the Food Safety and Standards Authority of India (Ministry of Environment, Forest, and Climate Change, 2022).</td><td>Plastic Waste Management Rules, 2016 stipulates that PIBOs are primarily responsible for the collection of packaging they introduce to the market. They are also required to register through the online portal of the Central Pollution Control Board and provide an action plan to address EPR targets (Ministry of Environment and Forests, 2016).</td><td>Compostable plastics are exempted from the thickness requirement, but shall conform with Indian Standard: IS 17088:2008 (Ministry of Environment and Forests, 2016).</td></tr><tr><td>Japan</td><td>The Plastic Resource Circulation Act, enforced in 2022, mandates retailers and service providers to reduce the use of single-use plastics. This can be through rewarding programs for consumers who refuse single-use plastics, charging for single-use plastics, or switching to alternative materials (Ministry of the Environment, n.d.).</td><td>Japan's Resource Circulation Strategy for Plastics, published in 2019, specifies a reuse/recycling target of 60% for containers and packaging by 2030 (Ministry of the Environment, 2019).</td><td>Under the current law, it is not mandatory for manufacturers to use recycled plastics. News last June 27, 2024, however, indicated that the Japanese Government is in the process of revising the Law for the Promotion of Effective Utilization of Resources, that is expected to obligate manufacturers to utilize recycled plastics (Kyodo News, 2024). Japan's Resource Circulation Strategy for Plastics specifies a target of doubling the use of recycled content by 2030 (Ministry of the Environment, 2019). Baseline values were not specified.</td><td>Japan's Resource Circulation Strategy for Plastics specifies a target of reusable/recyclable design for all containers and packaging by 2025 (Ministry of the Environment, 2019).</td><td>Under the Containers and Packaging Recycling Act, fully enforced in 2000, business operators are expected to properly recycle the packaging they produce or use for products, either through direct recycling, or by paying the recycling fee to the Japan Containers and Packaging Recycling Association (Hibiki, 2024). Small businesses are exempt from these recycling obligations (Japan Containers & Packaging Recycling Association, 2020).</td><td>Under the Plastic Resource Circulation Act, the Japanese government developed the "Guidelines for Design for the Environment" for manufacturers and established a mechanism to certify the products designed in accordance with the guidelines. The administration would preferentially procure such certified products (under the Act on Promoting Green Procurement) and provides financial support to those manufacturers (Tsuji, 2024).</td></tr></tbody></table>

(Continues)
<figure><img src="image_9.png" /></figure>

<table><caption>TABLE 1 (Continued)</caption><thead><tr><th>Country/state</th><th>Packaging prohibitions</th><th>Recycling targets</th><th>PCR requirements</th><th>Reuse/refill mandate</th><th>EPR obligations</th><th>Other requirements</th></tr></thead><tbody><tr><td>South Korea</td><td>"The Act on the Promotion of Saving and Recycling of Resources" mandates that disposable products, including PET bottles, plastic plates, utensils, and cups, must not be provided free of charge (United Nations Environment Programme, 2018). Ban on the use of PVC and colored PET bottles for water and beverages (US Department of Agriculture—Foreign Agricultural Service, 2022). Only colorless PET bottles have been permitted on the market, and labels for PET bottles have been recommended to be used only if consumers can easily remove them (Song & Park, 2024).</td><td>Partial amendments to the "Enforcement Decree and the Rule of the Act on the Promotion of Saving and Recycling of Resources" (2019) requires packages to be evaluated, graded (i.e., "best for recycling," "excellent for recycling," "normal for recycling," "difficult for recycling"), and labeled for recyclability (Song & Park, 2024; US Department of Agriculture—Foreign Agricultural Service, 2022). South Korea has a target to reduce its plastic waste by 50% and recycle 70% (Packaging Europe, 2024).</td><td>Recycled plastics could be used in food-contact sides if the recycled plastics are repolymerized through chemical recycling or comply with the "Standards for recycled synthetic resins used for manufacturing of utensils, containers, and packages" (Ministry of Food & Drug Safety, 2021). The Korean Government requires PET bottles to have a recycled content of 30% by 2030 (Lee et al., 2024).</td><td>When reusing food containers or packages by recollecting, they can be used only after confirming that there are no residual impurities, etc. by cleaning with water conforming to the Water Quality Standard as provided in the Drinking Water Management Act and by cleaning with cleaning materials, etc. conforming to the Hygiene Products Control Act (Ministry of Food and Drug Safety, 2021).</td><td>South Korea's EPR policy mandates all producers and importers of EPR items to collect and recycle the products/packaging materials (paper cartons, PET bottles, plastic composite films, metal cans, glass bottles, and expanded polystyrene) or pay allotted charges to the PROs (Korea Ministry of Environment, 2010). Small manufacturers and importers are exempt from recycling obligation (Korea Ministry of Environment, 2010).</td><td>Act on the Promotion of Saving and Recycling of Resources sets limits on the rate of packaging space and the number of package layers for food and beverage, cosmetics, detergents, groceries, quasi-drugs, clothes, electronics, and composite products.</td></tr><tr><td>Thailand</td><td>Thailand's Roadmap on Plastic Waste Management 2018–2030 sets a target of prohibiting the use of plastic bags (less than 36 microns) and foam food containers by 2022 (Ministry of Natural Resources & Environment, n.d.).</td><td>Thailand's Roadmap on Plastic Waste Management 2018–2030 sets a target to recycle 100% of plastic waste by 2027 (Ministry of Natural Resources and Environment, n.d.).</td><td>Per Notification No. 435, published by the Thai Ministry of Public Health, packaging made from recycled plastic must have its safety assessed and certified by a safety assessment agency (Ministry of Public Health, 2022). No specific recycled content requirements for packaging were found.</td><td>No specific reuse/refill mandate for packaging were found.</td><td>EPR is currently voluntary, but mandatory EPR might be soon realized with the Sustainable Packaging Management Act (in draft stage) (Lee, 2024).</td><td></td></tr></tbody></table>
<figure><img src="image_10.png" /></figure>

<figure><img src="image_11.png" /><figcaption>(b) PCoA of Regulatory Similarity</figcaption></figure>

<figure><img src="image_12.png" /><figcaption>(c) Dendrogram of Cluster Centroids</figcaption></figure>

<figure><img src="image_13.png" /><figcaption>**FIGURE 2** Clustering and similarity analysis of regulatory landscape based on features from Table 1. (a) Global map displaying regulatory complexity for selected countries and US states. Circle area is proportional to the square of the number of active regulatory features per entity, as defined in Table 1. (b) Principal coordinates analysis (PCoA) of Jaccard distances between entities based on the binary regulatory features in Table 1. Each point represents an entity colored by cluster membership and scaled by the square of the number of members in the corresponding cluster. (c) Dendrogram showing hierarchical clustering of the five regulatory clusters based on Euclidean distances between their centroids in the PCoA space.</figcaption></figure>
<figure><img src="image_14.png" /></figure>

The level of regulatory complexity is increasing globally, and the dominant trend is a gradual alignment toward the Cluster 1 profile. Even jurisdictions initially outside this cluster—such as Connecticut, Thailand, or New Jersey—are expected to transition closer to it, based on ongoing legislative reforms. The current structure suggests a regulatory momentum toward harmonization, with differences across blocks largely attributable to policy adoption timing rather than fundamental divergence.

## 3 | PROSPECTIVE IMPACT OF EMERGING REGULATIONS ON PRODUCT SAFETY

The global push by governments to mandate fully reusable, recyclable packaging and recycled content in plastic packaging indicates a significant shift toward closed-loop recycling systems for packaging materials, where materials are recovered and reused in the same or similar applications, rather than downcycled or discarded (see Table 1). However, amidst these efforts, critical questions arise about the impact on product safety, especially in sectors such as food. This section outlines several implications of emerging environmental regulations on product safety.

### 3.1 | Collection of plastic packaging in the EU and the United States

Successful plastic recycling requires consumer engagement, collection, sorting, reprocessing, and end markets. Among these, collection is crucial, as it directly affects the quality and safety of recycled materials. The selective/separate collection of plastic plays a pivotal role in the efficiency of the recycling systems. By increasing the amount of waste plastics suitable for recycling, coupled with the sorting by material recovery facilities (MRFs) as a further step, more materials of higher quality become available for reprocessing and utilization. Collection rates vary by region, with high-income areas like Europe and North America achieving higher rates, though rural areas often lag behind. Collection differs between post-industrial and post-consumer plastic waste. For example, specific plastic waste collection in the EU, supported by EPR, achieves rates of 90%-95%. For example, France's ADIVALOR program reported a 99% collection rate for agricultural plastics in 2023 (ADIVALOR, 2024). However, post-consumer plastic collection remains low, with only 26.9% collected and recycled in 2022. While EU regulations now require separate recycling streams, collection systems vary by country, including curbside pickup, drop-off centers, deposit-refund systems, and community-led initiatives (European Commission, 2022). In the United States, a 2015-2016 study found that 94% of residents had recycling access, with 73% using curbside programs (RRS & Moore Recycling Associates Inc., 2017). Historically, plastic recycling focused on PET and HDPE bottles, with limited progress on polypropylene and films (Auras & Selke, 2023). However, recent efforts aim to expand recycling capabilities.

No single collection method ensures maximum efficiency, as success depends on local conditions, economic factors, and education levels. However, dedicated plastic collection streams significantly improve recycling rates and reduce contamination (Lange, 2021). Future legislation like the PPWR should promote waste reduction and ensure effective collection and processing of plastic waste (European Parliament, 2024).

### 3.2 | Potential safety issues associated with the use of recycled packaging materials

Using recycled packaging expands the potential sources of contamination and can increase both the variety and levels of chemicals that may migrate from the packaging into the product (2013; Geueke et al., 2018, 2023; Muncke et al., 2017). Potential contaminants may include incidental contaminants from previous uses and consumer misuse (e.g., odor compounds and food residues). For polymers, contaminants may originate from non-food-grade polymers of the same type (e.g., household cleaners, motor oil, and additives used in the contaminating polymer), or from additives within the polymers themselves (e.g., pigments and stabilizers). Additional chemicals may form during the recycling, including non-volatile, which may be high molar mass molecules and be substances of very high concern (SVHC) and volatile organic compounds (VOCs) from polymer degradation, as well as other degradation products (Horodytska et al., 2020; Undas et al., 2023; Zeng et al., 2023). In a circular economy, tracking these chemicals is challenging, as it depends on how post-consumer fibers and plastics are collected—whether commingled with other materials or sorted—and how they are processed. This complexity is compounded when recyclable materials are sourced from different countries, making traceability even more difficult (Figure 3a).

Besides chemical contamination, recycling plastic can exhibit diminished mechanical and physical properties. High temperatures can partially degrade the polymer backbone during mechanical recycling, resulting in broken intramolecular bonds, reduced molecular weight, release oligomers, and altered mechanical properties (Colombo et al., 2024; Eriksen et al., 2019). Recycling processes often require additional additives and/or virgin polymers to offset these changes. However, residual additives and their breakdown products are likely to persist in the recycled plastic, potentially accumulating in the recycling stream and coupled with incidental contamination increase chronic exposure to high-concern contaminants, such as phthalates, toxic metals, brominated flame retardants (BFRs), and polyaromatic hydrocarbons with each recycling cycle (Undas et al., 2023). Consequently, local and global regulations must mandate approval processes for any recycled polymer or recycled technology used for polymer design to be in contact with products.
<figure><img src="image_15.png" /></figure>

<figure><img src="image_16.png" /><figcaption>**FIGURE 3** (a) Potential sources of contamination in the recycling process. (b) Risks associated with the reuse of plastic containers by consumers and stakeholders.</figcaption></figure>

## 3.3 | Potential safety issues associated with the utilization of reusable packaging

Reusable packaging, especially when used with food, cosmetics, and biological products, introduces additional safety challenges with potential implications for human health. These concerns span regulatory limits, functional properties, and contamination risks—whether chemical, physical, toxicological, allergenic, or microbiological. Hygiene standards, consumer misuse, and improper handling further add to the safety risks. To ensure safety, reused packaging requires stringent procedures at all stages, including during collection, sorting, washing, drying, transport, and filling (Figure 3b). These processes may be performed in whole or in part, depending on the product's intended use.

Cleaning and disinfection are critical to ensuring consumer safety by decontaminating packaging microbiologically before refilling. The cleaning process involves verifying washing conditions, such as temperature, mechanical aspects, and detergent concentration, to ensure the removal of the most resilient microorganisms, including those capable of biofilm formation or high thermal resistance, such as spores. Biofilms are structured communities of microorganisms adhering to surfaces, protected by a rigid extracellular matrix that makes them highly resistant to cleaning. They can form on various packaging surfaces, posing food safety risks due to microbial resistance to cleaning and stabilization treatments (Licciardello, 2024).

However, repeated sanitization with harsh chemicals to facilitate reuse may also introduce chemical contaminants, release micro and nanoplastics as well as promote aging, which could facilitate exposure of contaminants to consumers or accumulate in recycling materials (Auras & Selke, 2023). Being not inert, polymers can interact with food components, inks, and other environmental chemicals, and this interaction can change depending on the aging of the polymer, which may trigger different rates of micro and nanoplastics release. Depending on polymer characteristics and mutual affinities, contaminants may be absorbed into the polymer material and later released if decontamination is inadequate (Licciardello, 2024).

Currently, no definitive guidance is available for washing reusable packaging. However, industrial washing typically involves washing at temperatures ranging from 55°C to 65°C and rinsing at 70°C to 85°C, using detergents containing compounds like sodium hydroxide (Licciardello, 2024; Nahar et al., 2022). Higher temperatures may lead to enhanced decontamination levels, but, in the in situ glass transition temperature ($T_g$) of the plastic packaging (i.e., the $T_g$ experienced by the polymer when submerged in a solution) must be considered to avoid deformation during washing and premature release of compounds (Stormer & Guazzotti, 2025; Xu et al., 2022; Xu & Auras, 2025). Repeated industrial washing can compromise the mechanical properties of containers, potentially affecting machinability, logistics, and consumer acceptance.

The impact of reuse on the mechanical properties is also a concern for transport packaging formats (e.g., intermediate bulk containers, pallet wrappings, shrink wraps, and stretch films), which provide load stability during shipping. Under the latest EU proposed PPWR, economic operators in the EU must ensure that at least 40% of used transport packaging is reusable within a reuse system by January 2030 (European Parliament, 2024). However, the protective performances of these materials and formats diminish with each use, affecting transport safety (AIM European Brands Association et al., 2024).

## 3.4 | Safety assessment criteria for reused and recycled packaging

When assessing the safety of reused or recycled packaging materials, a comprehensive set of criteria is carefully evaluated to ensure regulatory compliance and minimize potential risks to consumer health. Regulatory standards vary in different jurisdictions, such as countries (e.g., the United States and Brazil) or trade regions (e.g., Mercado Común del Sur [MERCOSUR], North America Free Trade Agreement [NAFTA], and EU), each with
<figure><img src="image_17.png" /></figure>

<table><caption>TABLE 2 Surrogate contaminants recommended by Food and Drug Administration.</caption><thead><tr><th>Substance type</th><th>Substance</th></tr></thead><tbody><tr><td>Volatile polar</td><td>Chloroform<br>Chlorobenzene<br>1,1,1-Trichloroethane<br>Diethyl ketone</td></tr><tr><td>Volatile non-polar</td><td>Toluene</td></tr><tr><td>Heavy metal</td><td>Copper (II) 2-ethylhexanoate</td></tr><tr><td>Non-volatile polar</td><td>Benzophenone<br>Methyl salicylate</td></tr><tr><td>Non-volatile non-polar</td><td>Tetracosane<br>Lindane<br>Methyl stearate<br>Phenylcyclohexane<br>1-Phenyldecane<br>2,4,6-Trichloroanisole</td></tr></tbody></table>

Notes: The FDA does not recommend using heavy metal salts in surrogate testing for PET recycling, as migration of these substances has never been detected in food simulants. However, the FDA recommends heavy metal surrogate testing for non-PET recycling processes due to insufficient data on other polymers. In the case of polyesters, chloroform is a swelling agent. Adapted from Cecon et al. (2021).

its own specific approaches. This section outlines key regulations for recycled and reused packaging materials, focusing on those enforced in the United States and the EU.

### 3.4.1 | United States

In the United States, general guidelines exist for assessing the safety of reused packaging materials, although they are optional, and no regulatory framework explicitly addresses the cleaning and reuse of such containers. The industry often voluntarily applies cleaning standards similar to single-use containers, but this practice remains non-mandatory (Consumers Beyond Waste, 2021; ISO, n.d.). While not legally binding, the US Food and Drug Administration (FDA) Food Code offers guidance for refilling consumer-owned or third-party containers, requiring cleaning in a regulated food processing plant. Compliance involves designing containers for reuse, cleaning, sanitizing, and visual inspection by food establishment employees (Consumers Beyond Waste, 2021; US FDA, 2021).

Similarly, the FDA mandates that recycled plastics intended for food contact meet the same requirements as virgin ones (US FDA, 2021). While premarket clearance is not required for plastics produced via post-consumer recycling, FDA regulations focus on the composition of the plastic rather than on the production process (Misko, 2013). Although the use of recycled plastics that meet applicable authorizations does not necessitate action from the FDA, manufacturers can voluntarily submit recycling processes for review to ensure the recycled polymer achieves sufficient purity for its intended use. Key factors in assessing recycling efficiency include the source and quality control measures of the materials, the type of recycling process (e.g., primary, secondary, or tertiary), and the specific conditions used during the process, the intended purpose of the recycled material, and evidence of adequate purity (Fischer, 2023).

Contamination is generally not a concern for recycled materials undergoing primary or tertiary recycling. Primary recycling, which involves repurposing industrial or pre-consumer scrap produced from food-contact article manufacturing, poses minimal risk if Good Manufacturing Practices (GMPs) are followed (US FDA, 2021). Tertiary recycling or chemical reprocessing of post-consumer plastics, such as through methanolysis or glycolysis of PET and polyethylene naphthalate (PEN), yields purified monomers or oligomers suitable for food-contact use (US FDA, 2021).

However, recycled materials from secondary recycling—that is, recycling of post-consumer packaging—often require surrogate contaminant testing to ensure that low contaminant levels and purity are suitable for the intended use (US FDA, 2021). Surrogate contaminant tests assess the recycling process's effectiveness and the decontamination efficiency in percentages in removing incidental contaminants under worst-case conditions, aiming to keep residual levels to concentrations that will not pose health risks once converted to equivalent chronic exposure (US FDA, 2021). The FDA considers an estimated dietary intake (EDI) of contaminants from recycled food-contact articles at or below 1.5 µg/person/day (0.5 ppb or 0.5 µg/kg dietary concentration) to present a negligible risk (US FDA, 2021).

Surrogate contaminant testing involves exposing virgin plastic to selected surrogate contaminants. The FDA recommends representative surrogates, such as a volatile polar organic substance, a volatile non-polar organic substance, a non-volatile polar organic substance, a non-polar organic substance, and a heavy metal salt (except for PET) (US FDA, 2021). Table 2 shows examples of FDA-recommended surrogates, including
<figure><img src="image_18.png" /></figure>

chloroform—a swelling agent for most polyesters like PET and poly(lactic acid) but still listed in the US FDA (US FDA, 2021) and the EFSA (EFSA CEP Panel, 2024) as surrogates, and toluene for solvent residues, benzophenone as a proxy for non-volatile polar pesticides such as diazinon, and tetra-cosane for long-chain hydrocarbons like motor oil (US FDA, 2021). Careful consideration should be given when selecting surrogate contaminants to ensure they accurately represent real contaminants without causing excessive polymer modification.

Virgin plastic can be exposed to these contaminants either by filling containers with them or by soaking several kilograms of flaked virgin plastic in contaminated solutions (Fischer, 2023; US FDA, 2021). Once the containers are filled or after the contaminants are thoroughly mixed with the flakes, the bottles or flakes should be stored and sealed for two weeks at 40°C with periodic agitation. After the contaminants are drained and the bottles or flakes are rinsed, the concentration of each surrogate is determined in the polymer. The challenged polymers are then subjected to the proposed recycling process to be tested, and regenerated components or packaging material formed from the reprocessed polymer are analyzed for residual contaminants. For example, to attain an EDI level below 1.5 µg/person/day for recycled containers of 0.50 mm thickness, it is recommended that individual maximum residue levels of chemical contaminants remain at levels not exceeding 220 ppb (220 µg/kg) for PET with a density (δ) of 1.4 g/cm³, 320 ppb (320 µg/kg) for polyolefins with δ = 0.965, 300 ppb (300 µg/kg) for PS with a δ = 1.050 g/cm³, and 200 ppb (200 µg/kg) for PVC with a δ = 1.580 g/cm³ (Fischer, 2023; US FDA, 2021). These residual concentration limits are based on the FDA's "threshold of regulation" approach, accounting for factors like polymer density, polymer thickness, a consumption factor of 0.05, a food-type distribution factor of 1.0 for all food types, and 3 kg of daily food intake for an adult, assuming the finished article consists of 100% recycled polymer.

After the recycling process meets safety criteria, the FDA may issue a no-objection letter (NOL) for the specific process, confirming that the recycled material is of purity suitable for its intended use (Cecon et al., 2021). However, the NOL does not guarantee compliance; the responsibility for ensuring that the recycled material meets all applicable regulations remains within the manufacturer (Fischer, 2023).

### 3.4.2 | European Union

In the European Union, FCM are generally regulated under two main framework regulations: Regulation (EC) No. 1935/2004 and Regulation (EC) No. 2023/2006. Regulation (EC) No. 1935/2004 establishes the principle of inertness in Article 3, requiring that any material or object intended for food contact must not adversely affect human health. Regulation (EC) No. 2023/2006 mandates the industry to implement GMP and serves as the regulatory foundation for specific requirements on recycled materials and recycling processes. However, specific regulations and guidelines associated with these frameworks do not address the potential deterioration of materials, aging, or objects after multiple use cycles. Systemic health risks may accumulate over time or with aging of polymers without exhaustive risk assessments, such as verifying material stability, aging, and resistance to degradation under high temperatures, light exposure, or acidic and basic conditions.

Regulation (EU) No. 10/2011 focuses on plastic materials and articles intended to come into contact with food. It sets migration limits for initial substances and substances added to polymers to safeguard consumer safety. However, the regulation mandates testing only for three successive use cycles for reusable plastic packaging (RPP), which may not adequately capture long-term effects. Therefore, accelerated aging methodologies are needed to assess the safety of reused packaging, accounting for the physicochemical and surface changes that materials undergo during repeated use, helping to better predict how their properties evolve.

Controlling the interaction between the packaging and the product it contacts is essential regardless of packaging type. Both IAS and non-intentionally added substances (NIAS) can migrate from packaging into food, posing potential health risks. In the case of reused packaging, particular attention must be paid to stages like washing, which must not only remove any residues from previously stored products but also ensure that no harmful detergent residues are left behind.

Effective safety assessments of reused packaging should consider the following measures:

* Identify the chemical composition of the materials to determine whether they are likely to migrate, such as substances in inks, adhesives, and any other material in direct or indirect contact with the packaged product.

* Conduct migration tests or mathematics modeling, also called "migration modeling," to assess the substances likely to migrate under various conditions (e.g., temperature, storage time, product type, number of used cycles, and cleaning conditions).

* Define clear procedures for reused packaging, including cleaning, disinfection, and checking its integrity (absence of cracks, cuts, or other defects likely to promote the migration of chemical substances).

* Ensure compliance with international, European, and national regulations concerning the intended application (e.g., Regulation EU No 10/2011 for FCM).

For recycled packaging, the EU's requirements are specified in Commission Regulation (EU) 2022/1616, effective from September 2022, which repealed Regulation (EC) No 282/2008. This regulation mandates that only recycled plastic materials produced through approved recycling technologies—or novel technologies, pending approval—may be marketed. The recycling process must be shown to recycle waste into materials and articles that meet the general requirements in Regulation (EC) No. 1935/2004 and are microbiologically safe (European Commission, 2022).
<figure><img src="image_19.png" /></figure>

<figure><img src="image_20.png" /><figcaption>**FIGURE 4** Relationship between key parameters for the evaluation scheme under conservative scenario A (see Table 4), based on an exposure threshold value of 0.0025 µg/kg bw per day, factoring in a 5–10-fold overestimation for modeling. Depending on the molecular mass of the surrogate substance. Reproduced from EFSA Panel on Food Contact Materials, Enzymes & Processing Aids (CEP) (2024) under the CC BY-ND 4.0.</figcaption></figure>

Recycled plastic FCM must also meet the same compositional, restriction, and specification requirements as newly manufactured plastics under Regulation (EU) No. 10/2011 (European Commission, 2022).

Mechanical recycling technology must undergo a safety assessment by the European Food Safety Authority (EFSA). This assessment is achieved through a “challenge test,” which evaluates the recycling process’s effectiveness at reducing potential contamination, regardless of the contamination (EFSA CEP Panel, 2024). The “challenge test,” similar to the FDA’s surrogate contaminant test, uses thermally stable surrogate contaminants—if not, they should not be used—to evaluate a recycling process’s decontamination efficacy. Subsequently, the residual concentrations of these contaminants present in homogeneous contaminated flakes are measured to evaluate the effective decontamination rate (EFSA CEP Panel, 2024; Palkopoulou et al., 2016).

To ensure safety, it is essential to demonstrate that the recycling process effectively removes contaminants to a level that does not pose a risk to human health. This requires an estimate of the maximum concentration in the stream and control of non-FCM in the stream. For recycled PET, a maximum concentration of 3 mg/kg is assumed for a stream, and this should not include more than 5% of non-FCM. For non-evaluated substances, EFSA considers dietary exposure to contaminants below 0.0025 µg/kg body weight (bw) per day as posing a negligible risk (EFSA CEP Panel, 2024). The same principles hold for other polymers, but the maximum concentration in the stream should be adapted.

The concentration in food or food simulant could be determined experimentally; however, the reference value often falls below the detection limit achievable with conventional analytical techniques. Therefore, mathematical modeling under highly conservative assumptions is typically preferred. For instance, in the case of PET, the recycling process must reduce contamination in the input PET from a theoretical 3 mg/kg to a residual concentration ($C_{res}$) no higher than the calculated maximum allowable concentration ($C_{mod}$), resulting in a chronic dietary exposure of 0.0025 µg/kg bw per day. The $C_{mod}$ value can be calculated using any mathematical model that ensures scientific soundness and conservatism. The value of $C_{mod}$ varies across population groups, such as infants, toddlers, and adults. These scenarios are subsequently denoted A, B, and C. Figure 4 illustrates the relationship between the key parameters within this evaluation framework. While it is designed for broad applicability, certain criteria (e.g.,
<table><caption>**TABLE 3** Molecular mass (M~r~) and C~mod~ for common surrogate contaminants corresponding to migration levels for scenarios A, B, and C and calculated by diffusion modeling. These scenarios assume that the corresponding substance is non-evaluated-A priori genotoxic-And subjected to a maximum acceptable exposure of 0.0025 µg/kg body weight/day.</caption><thead><tr><th>Surrogate</th><th>Mr (Da)</th><th>C<sub>mod</sub> (mg/kg PET)<br>Scenario A</th><th>C<sub>mod</sub> (mg/kg PET)<br>Scenario B</th><th>C<sub>mod</sub> (mg/kg PET)<br>Scenario C</th></tr></thead><tbody><tr><td>Toluene</td><td>92.1</td><td>0.04</td><td>0.13</td><td>0.31</td></tr><tr><td>Chlorobenzene</td><td>112.6</td><td>0.05</td><td>0.15</td><td>0.60</td></tr><tr><td>Chloroform</td><td>119.4</td><td>0.05</td><td>0.16</td><td>0.63</td></tr><tr><td>Methyl salicylate</td><td>152.2</td><td>0.12</td><td>0.40</td><td>1.60</td></tr><tr><td>Phenylcyclohexane</td><td>160.3</td><td>0.13</td><td>0.42</td><td>1.69</td></tr><tr><td>Benzophenone</td><td>182.2</td><td>0.15</td><td>0.49</td><td>1.96</td></tr><tr><td>Lindane</td><td>290.8</td><td>0.28</td><td>0.92</td><td>3.67</td></tr><tr><td>Methyl stearate</td><td>298.5</td><td>0.29</td><td>0.95</td><td>3.82</td></tr></tbody></table>

Notes: Deviation of one unit of the last digit may occur when using different software.
Adapted from EFSA Panel on Food Contact Materials, Enzymes and Processing Aids (CEP) (2024).

diffusivities, chemical affinities, initial concentrations, and decontamination levels) are material specific and may not apply directly to other plastics, such as polyolefins like PP or HDPE (EFSA CEP Panel, 2018).

Table 3 displays C<sub>mod</sub> values for the typical surrogate contaminants found in PET. Scenario A is the most conservative, designed for infants (body weight of 5 kg and food intake of 0.75 kg/day); it covers food categories like water and baby bottle contents, such as reconstituted milk formula. Scenario B applies to other population groups consuming milk or non-alcoholic drinks and solid foods for infants and toddlers (food intake of 90 g/kg body weight/day for toddlers aged from 1 to 4 years). Scenario C, on the other hand, is the least conservative scenario, applicable to general food items not covered in scenarios A and B, assuming a body weight of 60 kg and a daily food consumption of 1 kg. These scenarios help determine the safety of PET recycling processes for various population groups.

### 3.4.3 | Comparison of the United States and EU safety criteria for reused and recycled packaging materials

The safety criteria for reused and recycled packaging between the EU and the United States have several similarities and differences. While both regions aim to safeguard consumer safety, they adopt distinct approaches and terminologies regarding these criteria (Nerin et al., 2025; Nerin, C. et al., 2025).

In the United States, the safety assessment of reused packaging materials is guided by general recommendations rather than mandatory regulations, and there is no specific regulatory framework governing the cleaning and reuse of such containers. The FDA's Food Code serves only as a guidance rather than an enforceable law, and states, cities, and counties can choose whether to adopt it into local laws. This decentralized regulatory system results in potential variations in food safety regulations across jurisdictions, including those for recycled and reused packaging. In contrast, the EU follows a more unified approach, with regulations for recycled and reused packaging harmonized across all member states. However, EU regulations and guidelines do not account for the potential degradation of materials or loss of functional properties after multiple use cycles, which could lead to safety issues if risk assessments are not sufficiently thorough.

For recycled plastics, the EU requires that the recycling process be authorized and assessed by EFSA before recycled materials are marketed. In contrast, the US FDA does not require independent regulatory review or premarket clearance for plastics produced through post-consumer recycling. Instead, the focus is on ensuring the final product composition complies with the same standards as virgin plastics for food contact. Although FDA review is not mandatory, many companies voluntarily seek FDA approval to maintain a competitive edge, and end-users often require proof of FDA's NOL from recyclers.

Both the United States and EU take comparable approaches to assess recycling process effectiveness, typically involving the contamination of virgin plastic with surrogate contaminants (of various molecular weights and polarities representative of possible classes of concern), running the contaminated plastic material through the recycling process, and then comparing initial and final concentrations. However, they diverge in their methods for establishing maximum exposure limits, the calculation and assumptions models used, and the safety margins applied (U.S. FDA, 2021; European Commission, 2022).

For instance, FDA uses the threshold of regulation approach in its risk assessment, which assumes that a compound is present in the whole diet at constant concentrations (Geueke, 2013). Conversely, the EU employs the Threshold of Toxicological Concern (TTC) approach, which requires a toxicological classification of substances (Geueke, 2013). The robustness of the TTC concept depends on the accuracy of substance classification
<figure><img src="image_21.png" /></figure>

and the specific toxicological endpoints considered. However, the reference contamination level for unknown contaminants in the input stream of PET may be outdated, as it was based on data from the FAIR-CT98-4318 project (Bayer et al., 2004). The EFSA has released new guidance on the TTC approach (EFSA Scientific Committee et al., 2019) while the FDA is conducting an external peer review of the Expanded Decision Tree (EDT): Ranking Toxic Potential. The EDT should serve as a science-based screening tool designed to systematically and consistently prioritize chemicals for evaluation. It represents a modernized version of the original Cramer Decision Tree, enhancing its applicability in risk assessment (Stice, 2025).

Protocols for PET, however, cannot be extrapolated to polyolefins (Palkopoulou et al., 2016). Purifying polyolefins is more challenging than PET due to their higher chemical sorption capacity and higher migration potential (Cecon et al., 2021; Palkopoulou et al., 2016). As polyolefins represent 70% of plastic packaging, establishing protocols for safe recycling is critical, especially given the increasing regulatory requirements for minimum recycled content in certain packaging materials. Recently, there has been a significant surge in FDA NOL applications for polyolefins, which previously focused primarily on PET (Fischer, 2023). In 2023, the FDA provided 25 NOLs for mechanical recycling, including 6 for PET, 16 for polyolefins (low-density polyethylene [LDPE], linear low-density polyethylene [LLDPE], high-density polyethylene[HDPE], and polypropylene [PP], 2023), and 3 for polystyrene (PS) (US FDA, 2024).

The differences in regulatory approaches and the current gaps in scientific understanding that inform essential safety thresholds could present challenges as the global shift toward a circular economy accelerates, with increasing reliance on recycled and reused materials in food-contact packaging, and the emerging of biodegradable and the trend of using food products and not only wastes to generate novel type of food-contact (bio)materials (EFSA Scientific Committee et al., 2023). This issue was highlighted in a workshop organized by the ILSI North America Food and Chemical Safety Committee in 2018, where an ILSI North America Member Scientist, noted that these divergent approaches could lead to compliance gaps, ultimately creating safety risks. Such gaps could be further exacerbated as more countries with varying regulatory structures join the transition to a circular economy (Karmaus et al., 2018). Further insights are provided in a recent review comparing key elements of risk assessment, particularly testing requirements, and emphasizing the need for global harmonization, given the consistent nature of substance migration and human health concerns (Nerin et al., 2025). The review outlines opportunities to align regulatory approaches, supporting improved risk assessment, risk management, and guiding future research and industry practices. Additionally, the 8th International Symposium on Food Packaging featured extensive discussions on testing recycled polymers such as PET, polyolefins, and potentially polystyrene across the United States, EU, and China (Huang, 2025; Kirchnawy, 2025; Nerin, C. et al., 2025; Stormer & Guazzotti, 2025; Welle, 2025; Zhong, 2025).

## 3.5 | Ongoing initiatives to ensure the quality of recyclates and reusable containers for consumer products

Various industry organizations have launched ongoing initiatives to ensure the quality and safe use of recycled and reusable containers in consumer products. These initiatives are discussed in the sections below.

### 3.5.1 | RecyClass and Association of Plastic Recyclers

RecyClass is a European non-profit initiative focused on improving packaging recyclability. It provides guidance and support to stakeholders in the plastic value chain through packaging design guidelines, recommendations for improving recyclability, an online recyclability assessment tool, and legal recyclability certifications (Design for Recycling Certification and Recyclability Rate Certification). The RecyClass certification system evaluates plastic packaging's compatibility with recycling on a scale from A to F and provides a percentage rating from 0% to 100% (RecyClass, 2024). Similarly, the Association of Plastic Recyclers (APR), a North American non-profit, aims to advance plastics recycling with design guides that classify packaging features by recyclability. Unlike RecyClass, APR offers recognition letters instead of certifications.

Table 4 details the recyclability categories used by the two organizations, highlighting notable differences in their assessment and categorization methods. Nevertheless, RecyClass and APR have agreed to collaborate on standardizing design guidelines and testing procedures to promote global consistency in recyclability standards. Once alignment is achieved, APR and RecyClass may issue mutually recognized certificates on both continents (APR & RecyClass, 2025). Following the approval of the PPWR, RecyClass updated its recyclability methodology to align with the new regulation, now recognizing only Classes A, B, and C to reflect stricter, harmonized standards. Classes A and B correspond to APR's "preferred" design for recycling, while Grade C aligns with "tolerated but needs improvement." (APR & RecyClass, 2025).

### 3.5.2 | COSPATOX consortium

Several sensitive applications now compete for the same recycled material streams. In particular, cosmetics and home-care packaging often rely on food-contact-grade materials for safety assurance, yet their post-use packaging typically cannot be reincorporated into food-contact applications via mechanical recycling—except in minor proportions (typically under 5%). This creates an urgent need for these sectors to develop their
<table><caption>**TABLE 4** Recyclability categories established by RecyClass and Association of Plastic Recyclers.</caption><thead><tr><th>RecyClass categorization</th><th>APR categorization</th></tr></thead><tbody><tr><td><ul><li>Class A: The packaging does not pose any recyclability issues, and the recycled plastics can feed a closed-loop scheme for the same quality application.</li><li>Class B: The packaging has some minor recyclability issues that slightly affect the quality of the recycled plastic generated. However, most recycled plastics from this packaging can feed a closed loop.</li><li>Class C: The packaging presents some recyclability issues that affect the quality of the recycled plastics or lead to material losses during recycling. In the first case, the recycled plastic could be used in a cascade open-loop scheme, whereas in the latter case, the plastic could potentially feed a closed-loop scheme.</li><li>Class D: The packaging has significant design issues affecting its recyclability or implying large material losses. In both cases, the recycled plastic can only be fed into low-value applications (i.e., the packaging will be downcycled).</li><li>Class E: The packaging has significant design issues that jeopardize its recyclability or imply severe material losses. The packaging is not considered recyclable and can only be used in incineration with energy recovery.</li><li>Class F: The package is not recyclable because of fundamental design issues or a lack of specific infrastructure for collection, sorting, and recycling in EU28+2.</li></ul></td><td><ul><li><strong>APR Design preferred:</strong> Package design features that are readily accepted by MRFs and recyclers since the majority of the industry has the capability to identify, sort, and process this feature with minimal or no negative effect on the productivity of the operation or final product quality. Packages with these features are likely to pass through the recycling process into the most appropriate material stream with the potential of producing high-quality material.</li><li><strong>Detrimental to recycling:</strong> Features that present known technical challenges for the MRF or recycler's yield, productivity, or final product quality but are grudgingly tolerated and accepted by most MRFs and recyclers. A package that contains any detrimental design feature is tolerated but needs improvement, so long as it does not contain any other features that render the package non-recyclable or require testing.</li><li><strong>Renders the package non-recyclable:</strong> Features that most MRFs or reclaimers cannot remove due to typical machinery settings or equipment capabilities. A package exhibiting this design feature will be completely discarded even if it has other preferred features. A package that contains any design feature that renders the package non-recyclable is non-recyclable.</li><li><strong>Requires testing:</strong> Requires testing per the APR testing protocol to determine the recyclability category.</li></ul></td></tr></tbody></table>

Note: Reproduced from Di Gregorio and Trenor (2023) and The Association of Plastic Recyclers (2024).

own robust safety standards tailored to **non-food-contact applications**, enabling the use of feeds that would otherwise be rejected by food-grade recycling constraints. Establishing such standards not only helps secure high-quality inputs but also guides the allocation of recycled materials to their most suitable uses, minimizing unnecessary downcycling and contamination risks. The COSPATOX consortium emerged with the objective of developing precisely this kind of methodology, focusing on the evaluation of recycled polyolefins for cosmetics and home-care products.

COSPATOX—an acronym for Cosmetics, Packaging, and Toxicology—is an industry-led European consortium comprising major brand owners, retailers, recyclers, plastics manufacturers, and converters (CosPaTox, 2024). It seeks to establish voluntary safety standards for high-quality post-consumer polyolefin recyclates, specifically for non-food-contact applications such as leave-on and rinse-off cosmetics, household detergents, and home-care packaging.

The project developed application-specific testing protocols and acceptable maximum exposure thresholds for substances in recycled polyolefins (PP, HDPE, and LDPE). These were evaluated across 30 diverse waste streams. Importantly, the COSPATOX approach demonstrated that meaningful safety assessments could be performed directly on recyclate pellets without the need to remanufacture test articles, enhancing the feasibility of large-scale implementation. While large-scale sampling challenges remain, the project validated the practicality of non-targeted screening on small samples (~3 g) coupled with semi-quantitative analysis, provided that comprehensive, continuously updated substance identification databases are used. This approach significantly reduces the number of unidentified substances that must otherwise be conservatively treated as potentially genotoxic.

The COSPATOX protocol addresses multiple toxicological endpoints and incorporates realistic exposure scenarios through calculation tools and reference spreadsheets. These tools account for packaging type, application (e.g., rinse-off vs. leave-on), target population, and migration behavior in model solvents (dichloromethane and hydroalcoholic media). The findings, made public in April 2024, form the basis of a forthcoming peer-reviewed publication, intending to foster broader uptake and harmonization beyond the food-contact domain.

### 3.5.3 | BUDDIE-PACK project

The EU-funded BUDDIE-PACK project, launched in September 2022, aims to develop and demonstrate sustainable strategies for RPP in the food and home-care sectors. It adopts a systemic, multidisciplinary approach integrating technological, social, and economic innovations for large-scale RPP deployment. The project involves five real-world business cases: (a) take-away packaging for meals from restaurants, canteens, or snacks; (b) supermarket catering packaging; (c) home-care detergent bottles paired with recyclable bag-in-box refill stations; (d) catering packaging for schools or nursing homes; and (e) raw meat skin-pack packaging for professional kitchens. The first phase shortlists suitable materials for each case (Farrell et al., 2024). The project implements accelerated aging protocols to ensure RPP quality and safety and tests functional properties, migration, sorption, and NIAS. It also evaluates potential microplastic release during washing (Buddie-Pack, 2025).
<figure><img src="image_22.png" /></figure>

### 3.5.4 | Emerging computational and AI-based tools to address the complexity of compliance testing in the circular economy

The safety evaluation of recycled materials, which cannot be considered identical to virgin ones, requires theoretical estimation of migration into food under a range of plausible exposure scenarios. As discussed in §3.5.2 (CosPaTox), this risk assessment must be repeated for all possible substances, whether evaluated or not. The complexity of stream composition—particularly in rubbery and polyolefin materials—and the wide diversity of food-contact applications (aqueous or fatty, hot or cold, and short or long contact) significantly complicate the task.

To address this, recent tools based on predictive algorithms, chemical and toxicological databases, and artificial intelligence have been proposed to accelerate and systematize compliance workflows. Two open-source projects illustrate this emerging trend:

* SFPPy (Vitrac, 2025a), a Python framework for modeling migration, exposure, and regulatory compliance across global legislations, and

* sig2dna (Vitrac, 2025b), a symbolic engine to transform analytical signals (e.g., GC-MS and FTIR) into DNA-like encodings for source identification, signal alignment, and contaminant fingerprinting.

These generative tools exploit large language models (LLMs) and generative simulation logic to produce realistic migration scenarios and infer contamination origins. Fingerprinting techniques derived from symbolic signal analysis enable the classification of materials (e.g., food contact vs. cosmetic contact), thereby supporting improved stream traceability and risk prioritization in a circular economy context.

## 4 | PROSPECTIVE IMPACT OF EMERGING REGULATIONS ON INTERNATIONAL TRADE

Emerging packaging regulations are expected to impact the dynamics of international trade. Examining the leading exporting nations is essential to assess the potential effects of these regulations. In 2022, China, the United States, and Germany emerged as key players in the export of goods, each dominating different sectors of global trade (World Trade Organization, 2023d). China's export industry primarily centers on electronics, including radio-telephony transmission tools and data processing machines. Meanwhile, the United States leads in exporting agricultural goods and petroleum products (World Trade Organization, 2023b, 2023c) while Germany specializes in exporting vehicles, machinery, and pharmaceutical products (World Trade Organization, 2023a).

As packaging regulations evolve to emphasize recycled content, recyclability, and reuse, industries face challenges adapting, particularly in sectors like electronics and automotive, where product fragility is a major concern during transit. Electronics are vulnerable to electrostatic discharge (ESD) damage, accounting for 25% of component failures and significant economic losses annually. Antistatic packaging, primarily made from polymers like PP and LDPE with added carbon black to reduce resistivity, mitigates these risks but presents challenges in meeting recyclability standards (de Souza Vieira et al., 2021). Additives like carbon black complicate waste sorting and recycling, while metalized shielding bags, made of multilayer materials, are difficult to process (Ge & Devar, 2017). The shift to sustainable packaging will require substantial investment in research, new materials, and updated manufacturing, potentially increasing costs, raising consumer prices, and creating trade barriers for countries unable to comply with new regulations.

New packaging regulations will significantly affect agricultural exports, which rely on packaging for protection, extended shelf life, and convenience. The US Farm Foundation's February 2024 report highlights the impact of plastic packaging restrictions on US exports to Canada, which imports over 75% of its fresh fruits and nuts and 60% of its fresh vegetables from the United States. The report warns that eliminating plastic packaging could disrupt nutritional access and food availability due to Canada's climate, increase fresh produce prices, and result in more food loss, waste, greenhouse gas emissions, and heightened food safety risks from pathogens like *Escherichia coli*, *Salmonella*, and *Listeria*, particularly for pre-cut or trimmed products (Grant & Legrand, 2024). Although a federal court invalidated the listing of "plastic manufactured items" under Canada's Environmental Protection Act on November 16, 2023, the motion granted on January 25, 2024 has paused the ruling while the government's appeal proceeds (Environment & Climate Change Canada, 2023a). However, a Federal Plastics Registry (FPR) has been created to collect data across the plastics value chain to track plastics from production to EoL, supporting transparency and evidence-based strategies to reduce plastic waste and pollution in Canada (Environment & Climate Change Canada, 2025).

Mandating recycled content in plastic packaging is expected to affect supply chains and international trade, raising concerns about the availability of food-grade recycled resins (Brown & Börkey, 2024). A study on PET bottles in South Korea predicts recycled PET supply will fall short of 2030 demands (Lee et al., 2024). Similarly, a 2017 survey by key industry groups revealed that PCR resin does not meet specifications (More Recycling, 2017). As regulations increase demand for high-quality recycled resins, initial shortages may increase prices, raising production costs and consumer prices. Low-income countries with underdeveloped recycling systems may face challenges meeting strict standards, limiting their exports and disrupting trade flows, potentially harming their economies (Martin, 2024).
<figure><img src="image_23.png" /></figure>

A recent letter from several associations to the EU Commission president highlighted concerns about the EU's new reuse requirements (Circular Economy Initiative et al., 2024). The letter warns that banning many single-use packaging types could disrupt European supply chains due to a lack of reusable solutions for many transport packaging formats, which are often neither viable nor compliant with transport safety standards. Additionally, the associations raised significant doubts about the ecological and economic feasibility of the changes and questioned their legal validity.

New packaging regulations may disrupt supply chains, especially in import-dependent countries, leading to price volatility, product shortages, and economic strain (Kummu et al., 2020; United Nations, 2023). The transition to compliant packaging could raise costs, affecting consumers and the availability of essential goods. To maintain global trade stability, governments, industries, and organizations must collaborate to address these challenges. Regulations must balance reducing waste and carbon footprints with ensuring the efficiency and resilience of the entire product/package supply chain.

## 5 | BEYOND WASTE AND SAFETY REGULATIONS—ARE WE HEADING TOWARD SUSTAINABILITY AND A CIRCULAR ECONOMY?

Evolving packaging regulations prioritize waste reduction and resource optimization through recycling, reuse, and recycled content but must also address energy use, water consumption, and greenhouse gas emissions. Life cycle assessment (LCA) and material flow analysis (MFA) are essential for evaluating environmental sustainability. LCA assesses environmental impacts across a product's life cycle, while MFA maps and quantifies resource flows to identify inefficiencies and waste (Auras & Selke, 2023; Graedel, 2019). Regulations must require LCAs for the entire product-package system to avoid unintended trade-offs, such as favoring recyclable materials with a higher production carbon footprint over less recyclable but more sustainable alternatives. While most countries focus on the environmental impact of the packaging, mostly at EoL, EPR systems like the one newly applied in Oregon have claimed to go beyond by planning to include an LCA of the product and packaging for the eco-modulated fees (Oregon State Senate Bill 582B, 2021).

Consumers often misjudge the environmental impact of packaging due to biases, favoring glass, bioplastics, and paper-based packaging as eco-friendly while viewing plastic and metal as less sustainable (Boesen et al., 2019; Fernqvist et al., 2015; Korhonen et al., 2015; Lindh et al., 2016; Steenis et al., 2017). For instance, De Feo et al. (2022) found that Italian consumers rated single-use glass as highly sustainable, yet LCA analysis showed it had the highest environmental impact. Similarly, Dolci et al. (2024) revealed that refillable glass is only environmentally favorable if reused at least 10 times in a short distance, with single-use plastic performing better below this threshold. Ferrara et al. (2021) supported these findings, noting that PET bottles were more sustainable than refillable glass with limited reuse, though impacts converged with higher reuse rates. Factors like waste treatment, recycled content, and transportation distances also significantly affect packaging sustainability (Lewis et al., 2024). Additionally, the impacts of reduced food shelf life and potentially higher food waste should be carefully considered, as food production has a far greater environmental footprint than food packaging.

The gap in consumer understanding of packaging's role and environmental impact often leads to misconceptions about sustainability and product/package selection (Vitrac et al., 2024). This highlights the need for consumer education, lifelong training of professionals in all affected sectors, and transparent communication from regulators and businesses. Educating consumers about packaging's essential functions—such as protecting and delivering safe, nutritious products—and using LCAs to assess overall sustainability can help them make informed choices. Additionally, clear, standardized labeling that conveys the complete environmental impact of the packaged product will further assist consumers and professionals to make sustainable choices and promote sustainable innovation. In this perspective, the open-source E-learning platform FitNESS (Vitrac et al., 2024), sponsored by the European Commission, provides one of the most comprehensive resources for sustainable food packaging education. This platform fosters collaboration across institutions, regularly updates content, and validates it with contributions from over a dozen European institutions.

## 6 | CONCLUSION

The global landscape of packaging regulations is undergoing a major transition toward circular economy principles, with, increasing requirements for reusability, recyclability, recycled content, and the elimination of harmful substances. These policies aim to reduce packaging waste, foster material recirculation, and shift responsibility upstream. Our analysis in Figure 2—based on regulatory features extracted from Table 1 and clustered using similarity metrics—reveals that despite regional disparities, countries are converging into a limited set of regulatory profiles. Five clusters emerge, reflecting different degrees of regulatory maturity, with Europe acting as a regulatory frontrunner, followed by coastal US states, parts of South America, and an accelerating response from Asian nations. The UNEP's endorsement of an international legally binding agreement to manage plastic waste signals a broader global momentum toward regulatory alignment at scale.

This transformation is driven by two intertwined but distinct forces:
<figure><img src="image_24.png" /></figure>

1. The drive for circularity, which demands reduced material use and enhanced material recovery; and

2. The imperative to maintain product safety, particularly in sensitive domains such as food contact, cosmetics, medical, and pharmaceutical applications.

While circularity promotes openness and flexibility in material flows, safety considerations impose stringent constraints due to the inherent complexity of recycled streams, unknown or non-evaluated contaminants, and strict exposure thresholds. These constraints require advanced traceability, decontamination, and recycled material authentication of recycled materials according to their intended use (e.g., long-term contact, high temperature, oily contact, and infant specific). Such conditions must be embedded upstream—into the collection, sorting and decontamination technologies—and demand coordinated investment in recycling infrastructure, harmonized safety standards, and data-driven systems for traceability.

One key to enhancing the competitiveness of circular materials, especially in high-purity or regulation-certain applications, lies in the global acceptance of technical rules and automation of compliance workflows along the value chain. Regulatory and risk-assessment organizations such as the US FDA and the EFSA in Europe continue to safeguard safety standards, but diverging regional approaches and differences in accepted materials add complexity. Greater international collaboration toward mutual recognition of testing methods, exposure modeling, and safety principles could accelerate global adoption.

In this context, one of us initiated the SFPPy project—an open-source Python framework for compliance and risk assessment—offers pathways forward. SFPPy integrates regulatory data from the EU, the United States, and China, and combines AI with toxicological and chemical databases such as PubChem to predict migration risks (Vitrac, 2025a). Similarly, the CosPaTox consortium, originally designed for cosmetic applications, proposes agnostic protocols that allow the redirection of recycled materials based on suitability rather than origin, thereby minimizing downcycling. When coupled with emerging tools such as sig2dna for signal-based contaminant and feedstock, these approaches enable AI-assisted compliance assessment fingerprinting recognition, and SFPPy for exposure and toxicological assessment can be leveraged to scale compliance assessments and inform sourcing decisions across sectors (Vitrac, 2025b).

Cooperation and mutual recognition between governments, industries, and civil society are essential to preserving international trade and supply chain resilience, while preventing the unintended “weaponization” of divergent regulations. Industries reliant on plastic packaging face new cost pressures and potential disruptions under the EPR schemes. Limited access to high-quality recycled resins and or advanced decontamination technologies may exacerbate competition between sectors and countries, especially in regions with immature waste infrastructure.

To adapt effectively, regulatory and industrial stakeholders must also consider the environmental footprint of the entire product/packaging system. LCA, combined with metrics such as food waste, energy use, and greenhouse gas emissions, remains central to supporting decisions that minimize harm. Educating consumers, enabling transparent regulatory communication, and cultivating science-based trust will facilitate an equitable transition to circularity.

Ultimately, the paradox of packaging—as both a critical safety barrier to contamination and a driver of environmental impact—cannot be addressed through technology alone. It demands an integrated and transdisciplinary educational effort. Bridging long-standing silos across material science (polymer, paper, metal, and glass), toxicology, food science and engineering, and sustainability engineering is essential. Initiatives such as the FitNESS platform mark important milestones by promoting shared, internationally recognized curricula in packaging safety, food technology, and circularity (Vitrac et al., 2024).

In this broader view, packaging must be reclaimed not as waste, but as a strategic asset. It supports global food and health security, reduces food loss, enables innovative distribution systems, and is central to the circular economy. Designing policies, infrastructures, and knowledge systems around this multidimensional role will ensure that packaging contributes not just to containment—but to resilience, safety, and sustainable transformation.

## ACKNOWLEDGMENTS

The authors gratefully acknowledge the support of the US Government Grant Award Number # SFR63022GR0031-M001 and the US Department of Agriculture Foreign Agriculture Service Grant Award Number # TASC-2022-14 - Technical Assistance for Specialty Crops Program CDFA: 10.604, for providing partial support for organizing the two key workshops, which were the seeds of the information and discussion provided in this forum article. The authors acknowledge the contribution of all the speakers and participants of the two workshops, which are the seed for creating this forum article. The first workshop, titled "Implications of the EU Packaging and Packaging Waste Directives on Creating and Adopting Sustainable Food Packaging Systems: A USA-France Interaction," took place on November 18, 2022 at University of Burgundy, Dijon, France. The second event, titled "Optimizing Packaging Systems' Safety for Reuse and Recycling in Compliance with the New Packaging and Packaging Waste Regulation," was held on November 9 and 10, 2023 at the University of Paris-Saclay, AgroParisTech, Palaiseau, France. C.S-P. acknowledges the support of the Republic of the Philippines for providing a DOST-SEI Foreign Graduate Scholarship. Disclaimer: This work was funded in part by a grant from the United States Department of State. The opinions, findings and conclusions stated herein are those of the author[s] and do not necessarily reflect those of the United States Department of State.
## CONFLICT OF INTEREST STATEMENT

The authors declare no conflict of interest.

## DATA AVAILABILITY STATEMENT

Data sharing does not apply to this article as no datasets were generated or analyzed during the current study.

## ORCID

Rafael Auras ID https://orcid.org/0000-0002-4378-359X

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**How to cite this article:** Saldaña-Pierard, C., Nguyen, P. M., Debeaufort, F., Vitrac, O., & Auras, R. (2025). Impact of emerging packaging regulations on international trade and product safety with emphasis on plastic reuse and recycling in Europe and North America. *Journal of Industrial Ecology*, 29, 1473–1504. https://doi.org/10.1111/jiec.70079