No Objection Letter for Recycled Plastics #66
June 1, 2001
Visy Plastics Pty Ltd.
268 Edwardes St., Reservoir
Dear Dr. Kosior:
This responds to your inquiry of February 18, 2000, and the additional information you submitted on February 8, 2001, requesting confirmation regarding the suitability of two methods for the secondary recycling of polyethylene terephthalate (PET) into food-contact articles intended for use in contact with dry (no surface fat or oil), aqueous, acidic, and low-alcohol (15% or less) foods at room temperature and below.
| | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | In your submission, you state that the source of the feedstock will be PET containers, including non-food PET containers, obtained from curbside collection programs (i.e., wo uld not include industrial PET containers such as 55 gallon drums that had previously held chemicals).
We have reviewed the information submitted to demonstrate the capability of the two processes to remove potential contaminants from post-consumer recycled PET (PCR-PET). You have provided analytical data on surrogate contaminants intentionally added to PET to represent contaminated post-consumer feedstock.
Based on our review of these data, we conclude that the levels of exposure to possible contaminants resulting from the proposed use of PCR-PET that was subjected to the two processes described in your submission would be below FDA's threshold of concern. Therefore, we conclude that these recycling processes will produce PCR-PET that is acceptable for use in contact with dry (no surface fat or oil), aqueous, acidic, and low-alcohol (15% or less) foods at room temperature and below, provided the PCR-PET complies with 21 CFR 177.1630. Although you specified that the source of the feedstock will be PET containers obtained from curbside collection programs, we would have no objections if the feedstock also included PET containers obtained from deposit recycling programs.
Our conclusion applies only to post-consumer PET containers obtained from deposit and curbside recycling programs and processed by the two methods described in the above submissions. If your recycling process is modified, new data would need to be evaluated.
Although we have concluded that the recycling process described in the above submissions will produce PCR-PET that is acceptable for the intended use, you should be aware that we are currently developing a formal policy on the use of post-consumer recycled plastics in contact with food. Thus, the decisions set forth in this letter may need to be modified due to future deliberations on this matter.
If you have any further questions concerning this matter, please do not hesitate to contact us.
Sandra L. Varner