G/TBT/W/786  
 
7 February 2024  
(24-1009) Page: 1/2 
Committee on Technical Barriers to Trade  Original: English  
 
 
THEMATIC SESSION ON FOOD CONTACT PLASTIC PACKAGING  
TENTH TRIENNIAL REVIEW  
Proposal from the United States  
The following submiss ion, dated 7 February  2024, is being circulated at the request of the  delegation 
of the United States . 
 
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1  BACKGROUND  
1.1.  Since 1995, more than 1,900 TBT notifications have included a reference to "plastics" . The 
scope of these measures spans  across the plastic s life cycle and includes  a wide array of policy tools. 
In recent years, many countries  have implemented mandates to reduce plastic packaging or produce 
plastic packaging material with recycled content.  However, measures intended to increase the 
sustainability of packaging may not take into account that adequate collection infrastru cture is 
needed to  achieve recycled content commitments . Such measures  may also have unintended 
consequences for food safety, the ability to reduce food loss and waste, and the ability to 
deliver/transport food, especially when packaging comes in contact w ith food products.   
1.2.  Food packaging1 serves a vital role in ensur ing food safety. Packaging protects food from 
contamination and spoilage, reducing the opportunity for foodborne illness. Packaging enabl es 
diverse food products to be transport ed and stor ed across longer distances and timeframes. 
Packaging also reduc es food waste and loss and ensur es better food access to underserved and 
vulnerable populations.  
1.3.  Some Members have implement ed or are in the process of implementing  measures  to reduce 
packaging materials and produce packaging material with recycled content  with environmental 
objectives in mind. T hese measures  have the potential to lead to significant changes in the way food 
is packaged nationally, regionally, and globally, with addition al changes forthcoming.  Additionally, 
the proliferation of divergent regulatory approaches at the national level may make implementation 
and compliance difficult in the context of global food trade and may discourage rather than promote 
efforts to reduce p lastic packaging materials and increase recycled content in  packaging material . 
1.4.  While recycled materials ha ve the potential to increase the sustainability of food packaging, 
these measures may inadvertently  create food safety and trade concerns that do not exist for food 
packaging made from virgin  material. Recycled material also presents a  new vector for the 
introduction of contaminants into food, through the use of recycled material from uncontrolled 
sourc es that were contaminated from non -food use s, reuse as non -food containers by the consumer 
prior to recycling, or through the waste collection process. Further, the availability of high -quality, 
recycled plastic resin or technical limitations to recycling certain plastics may pose additional 
challenges.   
 
1 The term "food packaging " includes packaging for both food and beverage that is in direct contact with 
the consumable product.  G/TBT/W/786  
 
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  1.5.  As Members seek to reduce plastic packaging and plastic waste, Members will need to rely on 
the fundamental principles of the TBT Agreement to develop  more effective and properly calibrated 
regulation s. Similarly, Members will need to consider the intersection between TBT -related 
environmental objectives and possible SPS -related externalities, as well as Codex Alimentarius 
standards and guidelines and collection policies,  when developing and implementing measures to 
reduce plastic packaging or produce plastic packaging material with recycled content .  
1.6.  Given the growing interest in combating plastic pollution and recognizing the important trade 
dimension of this challenge , it will be important to support  information sharing and best practices to 
take into account food -related challenges in the development of measures related to plastic 
packaging.  
2  PROPOSAL  
2.1.  The United States proposes to hold a thematic session that would explore the current landscape 
of Member  and stakeholder views and actions with regard to food contact packaging to 1) share best 
practices in the development of regulatory approaches to reduce plastic packaging and plastic 
packaging waste, including the importance of effective collection system s to achieve recycled content 
commitments ; 2) explore current technical and scientific information for food contact packaging 
including Codex -related standards or guidelines, alternative food packaging materials, and food 
packaging materials made from recy cled content; and 3) promote core TBT principles and good 
regulatory practices to reduce plastic waste and plastic pollution related to food contact packaging, 
without compromising food safety and food sustainability.  
2.2.  Topics and areas of focus could inclu de:  
a. Exploration of the types of commercial -scale technologies use d or currently under 
development to ensure the safety of recycled material suitable for use in food packaging ; 
and  
b. Challenges, limitations, and potential food safety implications of reducin g plastic packaging 
for food products and using recycled content in food packaging.  
2.3.  Within the context of these areas of focus, the proposed thematic session could enable:  
• Presentations by WTO Members to discuss how they take into account food safety and 
food sustainability when developing standards or technical regulations to reduce plastic 
packaging or increase recycled content materials in plastic packaging for food products;  
• Presentations by interested stakeholders, including Members, industry, interna tional 
organizations, academia, or non -governmental organizations, to share relevant research 
and technical information related to best practices for food packaging materials; and  
• Presentations by interested stakeholders that are developing or have develo ped and 
implemented approaches to promote reuse, recycling and innovation, including those that 
may involve certification or labeling  and voluntary initiatives  with a focus on identification 
of best practices to take into account food safety and food susta inability . 
 
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