No Objection Letter for Recycled Plastics #88
July 9, 2004
Roland Franz, Ph.D
Fraunhofer-Institut für Verfahrenstechnik und Verpackung
Giggenhauser Strasse 35
Dear Dr. Franz:
This letter is in response to your inquiry of August 5, 2003, requesting on behalf of your client, Sipa s.p.a. (Vittorio Veneto, Italy), FDA's opinion regarding the suitability of a bottle coating for recyclable polyethylene terephthalate (PET) bottles. This urethane-acrylate coating, manufactured by | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | | |. is to be applied by Sipa s.p.a. to the nonfood-contact layer of PET bottles and would be expected to enter the recycle system as part of the post-consumer PET recycle feedstock. As such, components of the coating could potentially become incorporated into the food-contact layer of post-consumer recycled (PCR) PET containers and subsequently migrate to food. This request has been logged into our tracking system as CTS 85732.
In your letter, you presented analytical testing data from feedstock consisting of PET bottles coated with the subject coating and recycled via either conventional wash-and-grind recycling processes or several "super clean" processes which involve high-temperature vacuum decontamination or solid-stating steps. Based upon this information as provided in your submission (CTS 85732), we have concluded that the introduction of PET bottles coated with | | | | | | | | | | | | |. coating into the recycling stream will not affect the capability of recycling processes to produce PCR-PET suitable for food-contact use. These recycling processes should consist of, at a minimum, the grinding of post-consumer PET bottles followed by washing and drying of the resultant flake. Please note that our conclusion applies only to the urethane-acrylate coating manufactured by | | | | | | | | | | | | |. and utilized in the test samples analyzed in this submission. If the formulation of this coating is significantly modified, new data would need to be evaluated.
If you have any further questions concerning this matter, please do not hesitate to contact us.
Paul Honigfort, Ph.D.
Consumer Safety Officer,
Division of Food Contact Notifications, HFS-275
Office of Food Additive Safety
Center for Food Safety
and Applied Nutrition