At every station: rules and costs
Recycled Plastic in Bread Trays: FDA Rules and Sustainability Trade-offs
Contents: 6 sections
A tray with recycled content can be suitable for food contact, but the supplier has to show it. Ask three things before you buy: where the recycled plastic came from, what the food-contact basis for that material is, and how the recycled-content tray compares with the virgin version in impact and cold tests. The lowest-risk source is scrap from the manufacture of food-contact articles, which FDA’s guidance treats as acceptable under good manufacturing practices; anything with a history of use needs more evidence. On the environmental side, what decides is the ratio between two numbers: how much recycled content lowers the emissions of making the tray, and how much it shortens the tray’s life in trips. A large manufacturing saving can survive a somewhat shorter life; a small one can be erased by a small rise in breakage, which your own records will show.
What does FDA require for recycled plastic?
The same purity standard as any other material, applied to a harder question. The federal rule for food-contact articles says: “Any substance used as a component of articles that contact food shall be of a purity suitable for its intended use” (21 CFR 174.5(a)(2)). For recycled plastic, the question FDA’s guidance singles out is what the material carried before: “The possibility that chemical contaminants in plastic materials intended for recycling may remain in the recycled material and could migrate into the food the material contacts is one of the major considerations for the safe use of recycled plastics for food-contact applications” (FDA guidance, 2021). That guidance is not binding; FDA says its guidances “do not establish legally enforceable responsibilities.”
FDA also looks at specific recycling processes when a company asks it to. Its recycled plastics page says: “FDA considers each proposed use of recycled plastic on a case-by-case basis and issues informal advice as to whether the recycling process is expected to produce PCR plastic of suitable purity for food-contact applications,” and it publishes a list of processes that received a favorable opinion (FDA, recycled plastics in food packaging). A favorable opinion covers a process, not your tray. The paperwork a supplier should give you for any tray, recycled or not, is set out in the food contact documents to request from a supplier.
Does it matter where the recycled plastic came from?
Yes, more than anything else. FDA’s guidance separates the cases:
| Source | What it is | FDA guidance | What to ask |
|---|---|---|---|
| Manufacturing scrap | Trim and rejects from making food-contact articles, never used; for example, a tray maker's own regrind from producing food-contact trays | "The recycling of this scrap is acceptable, provided good manufacturing practices are followed" | Confirm the scrap is from food-contact production, and how it is kept separate |
| Returned or end-of-life trays | Trays that have been in service, washed, stored and handled | Not the scrap case; they have a use history | What the trays carried and touched, how they are cleaned and sorted, and the food-contact basis for the resulting resin |
| Post-consumer plastic | Material collected from general recycling | The contamination question applies in full | Whether the process has an FDA favorable opinion, and for what uses |
Sources for the table: quoted text and definitions from the FDA guidance linked above, which defines primary recycling as “the recycling of industrial scrap produced during the manufacture of food-contact articles”; the rest is ours.
The middle row is where marketing language can blur things. “Post-industrial” is sometimes used for used trays collected from businesses, but a tray that has spent years on delivery routes is not manufacturing scrap. Drader, for example, runs a take-back program and says: “We collect your end-of-life post-industrial plastic products, including damaged or obsolete bread trays, milk crates, and warehouse bins,” and that the resin goes into “new, durable plastic products” (Drader, recycling). The page does not say whether that resin goes into food-contact trays. Programs like this are useful; for a tray that will touch bread, ask which products the resin goes into and on what food-contact basis.
Does recycled content weaken a tray?
It can, and the only numbers that matter are for the exact blend you are buying. Recycled resin has been melted and cooled at least once before and may carry traces of other plastics, and both can change how the finished tray behaves. Published percentages for strength loss vary with the source material and the blend, so a general figure tells you little about a specific tray.
Ask the supplier for test data comparing the recycled-content tray with the same model in virgin resin: impact strength, especially at your coldest temperature, and tensile strength. Then run your own test on samples: cold drops if trays go into a freezer, full-height loaded stacks, and a few weeks on real routes. How cold affects the resins themselves is covered in comparing HDPE and polypropylene in the cold and the washer.
A tray that breaks sooner has to be replaced sooner. Any saving on the purchase price has to be set against the replacement rate you see in your own retirement records, not against a supplier estimate.
What is the sustainability trade-off?
Recycled content can lower the emissions of making a tray, and breakage can take that gain back. A 2025 study of reusable produce crates, commissioned by the corrugated packaging industry, lists both in one sentence: “Impacts from the RPC system can be reduced by increasing reuse, incorporating recycled content, minimizing breakage and losses, and reducing transport distances” (<a href="https://www.fibrebox.org/assets/2025/10/CPA2025-CormparativeLCAFullStudy.pdf”>Corrugated Packaging Alliance, Anthesis, 2025). That study is about produce crates, not bread trays, but the arithmetic carries over.
Each trip carries a share of the tray’s manufacturing emissions: that figure divided by the trips the tray lasts. Suppose, as an illustration, that recycled content cut a tray’s manufacturing emissions by a fifth, but the tray lasted 150 trips instead of 200. Per trip, the recycled tray carries 0.8 ÷ 150 = 0.0053 of a virgin tray’s manufacturing emissions, against 1 ÷ 200 = 0.0050 for the virgin tray: slightly worse. With the same trip count, it would be a fifth better. The break-even point is where trips fall by the same fraction as manufacturing emissions: at 0.8 of the emissions, the recycled tray needs at least 0.8 × 200 = 160 trips to match the virgin tray per trip. So the environmental case for recycled content rests on two numbers you can check: the supplier’s manufacturing emissions figure for each version, and the trips per tray your fleet actually gets from it. How to count those trips is in measuring your tray program’s carbon and waste per trip.
Two more checks belong with any recycled-content claim:
- What the claim means. The FTC’s Green Guides say “It is deceptive to represent, directly or by implication, that an item contains recycled content unless it is composed of materials that have been recovered or otherwise diverted from the waste stream, either during the manufacturing process (pre-consumer), or after consumer use (post-consumer),” and that for pre-consumer material “the advertiser should have substantiation that the pre-consumer material would otherwise have entered the waste stream” (16 CFR 260.13). Ask which kind the percentage is, and on what records it rests; this is also the split between manufacturing scrap and used plastic that matters for food contact above.
- Where the plastic goes next. A take-back program that turns retired trays into new trays keeps the material in the same use; one that turns them into other products does not. Ask which it is before you count it in a sustainability report.
What should you ask the supplier?
Get written answers to these before you order:
- What percentage is recycled, and from which source: manufacturing scrap, returned trays, or post-consumer material?
- What is the food-contact basis for the recycled material? A favorable FDA opinion on the recycling process (which one), or the supplier’s own determination, and on what evidence.
- How is the feedstock controlled? How are non-food plastics and contaminated material kept out?
- What test data compares the tray with its virgin-resin version for impact, including at low temperature, and tensile strength?
- Has the tray been checked for odor transfer to your kind of product?
- Is the recycled percentage tracked by production lot, and can you get lot records?
- If there is a take-back program, does the reclaimed material go back into food-contact trays or into other products?
A supplier who answers the first two in writing with specifics has done the work. A general statement that the material is “food grade” is not an answer to either.
Should you buy trays with recycled content?
Yes, where the source is manufacturing scrap from food-contact production and the supplier’s test data holds up against the virgin version in your own sample tests. For trays made from returned or post-consumer material, buy only with a written food-contact basis for that material and test data for that blend, and treat the environmental claim as something to check against your own breakage records after a year. Where the trays sit in the rest of the buying decision is in the full tray selection sequence.