No Objection Letter for Recycled Plastics #109
May 23, 2007
Global P.E.T., Inc.
353 E. Ellis Avenue
Perris, CA 92570
Dear Mr. Bahou:
This is in response to your submission, received on 16 April 2007 (logged in as CTS 72539), requesting on behalf of Global P.E.T., Inc. an opinion letter from the FDA regarding the use of post-consumer, recycled polyethylene terephthalate (PCR PET) flake in the manufacture of single layer trays, containers, clamshells, and others for use in direct contact with raw fruits and vegetables and shell eggs (which would be peeled and/or washed before consumption) for short periods of time at room temperature or below (i.e. conditions of use E through G, as described in Table 2 on our website: http://www.cfsan.fda.gov/~rdb/opa-fcn3.html).
You indicated that the feedstock subjected to the proposed recycling process contains only post-consumer carbonated soft drink and water PET bottles. The feedstock excludes juice, sport drinks and other multi-layer structures that may contain oxygen and UV barriers (such as nylon, ethylene vinyl alcohol, and ethylene vinyl acetate), and also excludes industrial containers. The proposed process is a typical secondary recycling process, which includes manual sorting, metal separation, a hot-caustic wash and surface drying, and melt-filtered extrusion equipped with a vented barrel to remove gases and volatiles, for the production of PCR PET sheets used in the manufacture of the proposed-use food-contact articles.
Based on our review of the information provided, we determined that because of strict source control, there is little likelihood of unacceptable contaminant levels in your PCR PET. Therefore, we conclude that the proposed recycling process described in the 16 April 2007 submission would produce PCR PET that would be acceptable for use in direct contact with raw fruits and vegetables and shell eggs (which would be peeled or washed before consumption) for short periods of time at room temperature or below (i.e. conditions of use E through G, as described in Table 2 on our website: http://www.cfsan.fda.gov/~rdb/opa-fcn3.html) as long as the PCR PET is obtained from strict source control of a feedstock consisting of post-consumer carbonated soft drink and water PET bottles (e.g. feedstock would not include non-food PET containers and industrial PET containers) and the PCR PET complies with 21 CFR 177.1630. If Global P.E.T. Inc.’s recycling process is modified, new data would need to be re-revaluated.
If you have any further questions concerning this matter, please do not hesitate to contact us.
Vanee Komolprasert, Ph.D., P.E.
Consumer Safety Officer
Division of Food Contact Notifications, HFS-275
Office of Food Additive Safety
Center for Food Safety
and Applied Nutrition