Integrating PCR

Using PCR in Food Grade Applications

Plastic is used for packaging of almost every type of product from food and drinks to cleaning supplies and durable goods. In order to ensure that recycled plastic used in food contact applications is safe for consumers, the U.S. Food and Drug Administration (FDA) has a means for reviewing recycling processes used by recycled resin producers. The FDA evaluates the processes, test results and the proposed conditions for the use of the plastic to ensure that any contaminant concentrations do not migrate from plastic into food and result in dietary concentrations that exceed a negligible threshold (less than 0.5 parts per billion).

The packaging is approved for the type of food, the duration of contact and the range of temperature applications from freezing up through high oven temperatures. It is important to note that a favorable determination for a given condition does not mean the package is suitable for other applications.

The FDA issues favorable opinions through No Objection Letters (NOL) which are also commonly referred to as LNO’s within the industry. As of September of 2022, there were 271 NOL’s listed in the FDA’s searchable database. While the vast majority of those listed are for PET, there are multiple listings for other resins including HDPE, LDPE, PP, and PS. Food grade recycled resins are most commonly available for PET (rPET), but natural HDPE and others are increasing in availability.

Suppliers are also developing solutions that use various manufacturing techniques to embed recycled materials between layers of virgin materials. These layering techniques can be implemented for both rigid and flexible packaging solutions. The FDA has established “an effective barrier” thickness for PET at different conditions and offers guidance for studies with other resins. Advanced recycling technologies (also referred to as chemical recycling) produce resins that are comparable to virgin resins and, thus, suitable for food contact. Many of these technologies can also tolerate high levels of food residue.

References:

• Searchable list of No Objection Letters
• Guidance for Industry: Use of Recycled Plastics in Food Packaging (Chemistry Considerations)
• Food Types & Conditions of Use for Food Contact Substances

Converter Preparation

Choose a converter that is ready and able to integrate PCR by focusing on:

• Available capacity – potentially requires changeovers along with running at a reduced rate
• Infrastructure to bring in material – this can drive additional cost
• Previous experience with PCR – ensures the converter has sufficient knowledge of PCR needs
• Technical expertise – to problem solve development issues
• Understands the value of PCR and has a willingness to think outside of the box

On-Pack Labeling

Before any claim of recycled content is made on-package, consult the Federal Trade Commission (FTC) Green Guides to ensure compliance.

A growing number of American consumers are looking to buy environmentally friendly “green” products from recycled paper to biodegradable trash bags. Companies have responded with “green” marketing touting the environmental benefits of what they’re selling. But sometimes what companies think their green claims mean and what consumers really understand are two different things. The Federal Trade Commission’s Green Guides are designed to help marketers avoid making environmental claims that mislead consumers. States may have different requirements in addition to the federal Green Guide recommendations.

The Green Guides were first issued in 1992 and were revised in 1996, 1998, and 2012.

Green Guides Update in 2023

The guidance they provide includes:

1. general principles that apply to all environmental marketing claims;
2. how consumers are likely to interpret particular claims and how marketers can substantiate these claims; and
3. how marketers can qualify their claims to avoid deceiving consumers.

The FTC’s most recent update of the Guides is designed to make the guidelines easier for companies to understand and use. The changes include new guidance on marketers’ use of product certifications and seals of approval, claims about materials and energy sources that are “renewable,” and “carbon offset” claims.

The Federal Trade Commission announced that it is seeking public comment on potential updates and changes to the Green Guides for the Use of Environmental Claims. The Commission’s Green Guides help marketers avoid making environmental marketing claims that are unfair or deceptive under Section 5 of the FTC Act. The Commission seeks to update the guides based on increasing consumer interest in buying environmentally friendly products.

The U.S. Pact will be providing comments to the FTC to shape the next version of the Green Guides.

Questions about the U.S. Pact’s PCR Toolkit? Contact: takeaction @ usplasticspact.org