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  6. Letter to Retailers, Distributors, and Importers of Dinnerware
  1. Post-market Determinations that the Use of a Substance is Not GRAS

Letter to Retailers, Distributors, and Importers of Dinnerware

May 8, 2025


Dear Retailers, Distributors, and Importers of Dinnerware:

The U.S. Food and Drug Administration (FDA or “we”) is issuing this letter to inform you that dinnerware manufactured from the sheath of leaves from the Areca catechu (A. catechu) plant may not lawfully be offered for sale in the U.S.

Specifically, dinnerware such as bowls, plates, cups and cutlery manufactured from the leaf sheath of the A. catechu plant, which are often termed “palm leaf plates” or “palm leaf dinnerware”, demonstrate the potential to leach toxic chemicals when tested under conditions designed to mimic their use in contact with food, according to laboratory tests conducted by FDA scientists.1 These chemicals, known as alkaloids, naturally occur in various parts of the A. catechu palm plant including the leaf sheath, and have been shown to cause a variety of negative health effects when ingested, including cancer. 2, 3, 4

Plant-derived materials are generally considered safe for food-contact use, and FDA has historically not objected to the use of plant-based food-contact products provided they are of a purity such that they do not pose a safety concern.  However, the use of the sheath of A. catechu palm leaves in food contact articles such as dinnerware does not meet the statutory criteria for general recognition of safety (GRAS).5 This evaluation is based on scientific data and information demonstrating a potential safety concern for dietary exposure to known alkaloid constituents of the A. catechu palm leaf as a result of its use in dinnerware.  The use of A. catechu palm leaf material in dinnerware is not GRAS and no authorization exists for its use in contact with food, and such use is an unsafe food additive as defined under Section 409 of the Federal Food, Drug and Cosmetic Act (FD&C Act - 21 U.S.C. 348(a)).  Food contact products, such as dinnerware, that bear or contain an unsafe food additive are adulterated under 21 U.S.C. 342(a)(2)(C)(i).  

FDA has placed all dinnerware products manufactured from the sheath of leaves from the A. catechu plant on an import alert (IA 23-15) to help prevent the importation of these products for sale in the U.S. market.  Additionally, retailers, distributors, and importers of dinnerware are responsible for ensuring the products they market, distribute, or import for use in contact with food are safe for their intended use and comply with all FDA regulations.  Therefore, we urge retailers, distributors, and importers of dinnerware to take the necessary steps to confirm that their products are not manufactured from the leaf sheaths, leaves, or other parts of the A. catechu palm plant.  As the health concern for palm leaf dinnerware results from long-term use and is not an acute public health concern, FDA is currently not directing retailers of these products to take steps to recall products that have already been sold to consumers.  Offering an adulterated product for sale in interstate commerce is a prohibited act under the FD&C Act, and the FDA will take action as appropriate when violative products are found on the U.S. market or are inspected prior to import into the U.S.  

This current evaluation is specific to dinnerware manufactured from parts of the A. catechu palm and does not apply to dinnerware made from other plant-derived material.  Retailers, distributors, and importers are encouraged to consult with the FDA regarding the safety and regulatory status of any products that they market, distribute, or import for use in contact with food.  There are no effective authorizations for food-contact uses of products manufactured from the sheath of A. catechu leaves.  Firms interested in offering dinnerware made from the leaf sheaths of the A. catechu palm plant for sale in the U.S. may submit a pre-market notification for a food contact substance (FCN) in the form specified in Title 21 of the Code of Federal Regulations part 170.100 (21 CFR 170.100) to the FDA.

Questions for FDA related to this topic can be sent to premarkt@fda.hhs.gov.

Sincerely,

/s/

Kristi Muldoon-Jacobs, Ph.D.
Director
Office of Pre-Market Additive Safety (OPMAS)

Related Information

1.  Mangrum, J. B., DeJager, L., and Begley, T. (2025). Investigation into the presence of alkaloids in Areca catechu based single use food-contact articles (FCA). Food Additives & Contaminants: Part A, 1-13, https://doi.org/10.1080/19440049.2025.2469271.
2. Wang, C. K., Lee, W. H., & Peng, C. H. (1997). Contents of phenolics and alkaloids in Areca catechu Linn. during maturation. Journal of Agricultural and Food Chemistry, 45(4), 1185-1188.
3. See memorandum on the sheath of Areca catechu palm tree leaves in food contact articles – April 24, 2025. Posted on FDA’s website “Post-market Determinations that the Use of a Substance is Not GRAS”. Accessed 5/8/2025.
4. Bhide SV, et al. (1984) Arecoline tumorigenicity in Swiss strain mice on normal and vitamin B deficient diet. J Cancer Res Clin Oncol 107:169-171.
5. See FDA’s website “Post-market Determinations that the Use of a Substance is not GRAS”. Accessed 5/8/2025.

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