Food

No Objection Letter for Recycled Plastics #68

Return to inventory: Submissions on Post-Consumer Recycled (PCR) Plastics for Food-Contact Articles

See also Recycled Plastics in Food Packaging


June 13, 2001

Roland Franz, Ph.D.
Fraunhofer-Institut for Process Engineering and Packaging
Giggenhauser Strasse 35
D-85354 Freising
GERMANY

Dear Dr. Franz:

This responds to your inquiry of August 3, 2000, requesting on behalf of your client, Bühler AG, our opinion on the suitability of a secondary recycling process for producing post-consumer recycled (PCR) polyethylene terephthalate (PET) to be used in the manufacturing of food-contact articles intended for use in contact with all types of food under Condition of Use C (i.e., hot filled or pasteurized above 150° F) and less severe conditions. The subject process includes  | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |  In your submission, you state that the source of the feedstock will be food and non-food PET containers, but will not include industrial PET containers.

We have reviewed the information submitted to demonstrate the capability of the subject process to remove potential contaminants from 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 process described in your submission would be below FDA's threshold of regulatory concern. Therefore, we conclude that this recycling process will produce PCR-PET that is acceptable for use in contact with all types of food under Condition of Use C and less severe conditions, provided the PCR-PET complies with 21 CFR 177.1630. Our conclusion applies only to post-consumer PET containers processed by the method described in the above submission. If your recycling process is modified, new data would need to be evaluated.

Although we have concluded that the intended use of PCR-PET that has been collected and processed by the method described in your submission is acceptable, 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.

Sincerely yours,

Sandra L. Varner
Acting Director,
Division of Petition Control, HFS-215
Center for Food Safety and Applied Nutrition

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