WTO Circulates Notification of Brazil's Draft Resolution on Health Requirements for Food-Grade Post-Consumer Recycled PET

April 1, 2025

On April 1, 2025, the WTO circulated Brazil’s Draft Resolution 1317, outlining health requirements for food-grade post-consumer recycled polyethylene terephthalate (PET-PCR) used in food-contact packaging. The resolution sets safety, approval, and labeling standards for PET-PCR materials and manufacturing establishments, incorporating Resolution GMC/MERCOSUR. The final date for comments is May 19, 2025.

The Draft includes the following chapters:
Chapter 1: Preliminary Provisions
-Establishes sanitary requirements for food-grade PET-PCR, precursor items for PET-PCR packaging, and food-grade PET-PCR packaging intended for food contact. Key definitions include ""food-grade PET-PCR,"" ""special authorizations for use"" (No Objection Letter - NOL), and ""incidental contamination.""
Chapter II: Basic Requirements for Safety and Approval of PET-PCR Grade Food, Precursor Articles, and PCR-Grade PET Packaging
Chapter III: Requirements for Establishments Manufacturing Precursor Articles and Food-Grade PET-PCR Packaging
Chapter 4: Labeling
Chapter 5: Final Provision: Stipulates that non-compliance with the resolution’s provisions constitutes a health infraction under Law No. 6,437 of August 20, 1977, with potential civil, administrative, and criminal liabilities.

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South America

News Market:

Brazil

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World Trade Organisation (WTO)

Brazil

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Aspect	USA	EU	Australia	China	UAE
Regulatory Authority	FDA	EFSA & Member State Authorities	FSANZ	SAMR & NHC	ESMA & MOHAP
Major Regulation Governing Compliance	Federal Food, Drug, and Cosmetic Act (FFDCA); 21 CFR Part 110 (Current Good Manufacturing Practices)	Regulation (EC) No 178/2002 (General Food Law); Regulation (EU) No 1169/2011 on Food Information to Consumers	Food Standards Code (Australia New Zealand Food Standards Code)	Food Safety Law of the People's Republic of China (Revised 2015); GB Standards for Food Safety	UAE.S GSO 9:2017 (GCC General Requirements for Prepackaged Food)
Pre-market Approval Required?	No pre-market approval except for novel ingredients, color additives, or specific claims	No pre-market approval for general foods, but novel foods or health claims require EFSA approval.	No pre-market approval unless it's a novel food or makes health claims	Pre-market registration is required for novel foods, health foods, or products with new ingredients	Pre-market approval is required for certain foods, health products, and products with new ingredients
Processed Food Labeling Compliance /Labeling Requirements	Mandatory labeling as per FDA guidelines (Nutrition Facts, Ingredient Declaration, Allergens)	Must comply with EU Food Information Regulation (1169/2011); includes allergens, nutrition, and origin labeling.	Must follow FSANZ Food Standards Code for labeling; nutrition panels, allergens, and ingredient lists required	Must follow GB 7718-2011 (National Food Safety Standards) for labeling; mandatory nutrition facts, allergens, and shelf-life	Must follow GSO 9:2017 for pre-packaged food labeling; Arabic labeling, allergens, and nutrition facts required
Timeline for Registration	No fixed timeline: products can enter the market once compliant	No formal registration unless novel food; EFSA approval for health claims takes 12-18 months	No formal registration unless it's a novel food or makes health claims	Typically, 12-24 months for novel foods, shorter for regular processed foods	Approval may take 6-12 months for certain products. Regular processed foods can enter the market once label approval is obtained

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