No Objection Letter for Recycled Plastics #0026
August 24, 1994
Mr. Ralph A. Simmons
Keller and Heckman
1001 G Street, N.W.
Suite 500 West
Washington, D.C. 20001
Re: Food Additive Master File 553
Dear Mr. Simmons:
This is in response to your submissions of August 18, 1993, and January 6, 1994, and Mr. Heckman’s submission of May 19, 1994, on behalf of Johnson Controls, Inc., concerning the use of recycled post-consumer polyethylene terephthalate (PET) to manufacture new food containers. The recycled PET containers are intended to be used in contact with all types of food under condition of use A (high temperature, heat sterilized or retorted over 212°F). You stated that the recycled post-consumer PET will be obtained from soft-drink bottles or other food-contact containers and processed by Johnson Controls’ XXXXXXXXXXXX process described in Food Master File 553.
The information you have provided describes, in detail, the Johnson Controls’ recycling XXXXXX XXXX XXXXXX XXX XXX XXXXX procedure for converting post-consumer PET food containers to new PET food containers. Based on our review of this information and other information in our files, we conclude that the process described in your submissions is effective at reducing the level of most contaminants intentionally added to PET to levels equivalent to a dietary concentration of less than 0.5 parts per billion (ppb). Therefore, because exposure to possible contaminants from the proposed recycling process would be below the threshold of regulation (0.5 ppb), we conclude that food-contact use of Johnson Controls’ recycled PET would not require an amendment to the food additive regulations.
Our conclusion applies only to PET treated as described in your submissions. The commercial process should be equivalent to the process described in your submissions. If the commercial process is not equivalent, new data may need to be evaluated.
Although we have concluded that your intended use of recycled PET does not require an amendment to the food additive regulations, 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 related to this letter, please do not hesitate to contact us.
Eugene C. Coleman
Division of Petition Control
Center for Food Safety
and Applied Nutrition