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No Objection Letter for Recycled Plastics #0014

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

See also Recycled Plastics in Food Packaging

November 19, 1992

Mr. Robert G. Wick
Product Line Manager
Menasha Corporation
P.O. Box 508
Watertown, Wisconsin 53094-0508

Dear Mr. Wick:

This responds to your letter of September 4, 1991, concerning the reuse of post-consumer polyethylene and polypropylene containers to fabricate new containers for storing and shipping poultry, red meat, and seafood.

Your letter states that the post-consumer polyethylene and polypropylene resins are collected from damaged poultry, red meat, and seafood shipping containers. The containers are XXXXXX XXXXX XXXXXXXXXXX XXX XXXXXXXXXXX XXXXXXXXXXXXX XXXX XXXXXXX XXXXX XXXXXXXXX XXXXXX XXXXXXXXXXX XXXXXX XXXXX XXX XXXXXX XXXXXXXX XXXXXXXXXXX XXXXXXXX XXXXX XXXXXXX XXXXXX XXXXXXXX XXXX X XXXX XXXXXX XXXX XXXXXX XXXXXXX XXXXXXXXXX XXXXXX XXXXXXXXXXXX XXXXXXX XXXX XXX XXX XXXXX XXXXXXXXXXXXX XXXXXX XXX XXXXXX XXXXXXX XXXXX XXXXXX XXX XXXX XXXXX XXXXXX X XX XXXX XXXXX XXXX XXXXX XXXXXXXXX XXXXXXXXXX XXXXX XXXXXXX XXXXX XXXXXXXX XXXX XX XXX XXXXXX XXXXX XXX XX Your letter also states that processed uncooked poultry, red meat, and seafood are placed into the containers and cooled with ice or carbon dioxide. The meat may remain in direct contact with the containers up to five days under refrigerated temperatures.

We conclude that your proposed use of post-consumer polyethylene and polypropylene resins to fabricate containers to ship refrigerated poultry, red meat, and seafood would not require a food additive petition to the Food and Drug Administration (FDA), because the containers will be made from resins that are currently regulated for food-contact use and the control of the source resins makes it unlikely that unacceptable contaminant levels would be present in the resins. However, if any adjuvants are used in the blending of the virgin and recycled resin to form the recycled containers, those adjuvants and their levels of use must comply with the appropriate regulations. The use of unregulated adjuvants, or the use of regulated adjuvants at levels higher than those allowed in FDA’s applicable food additive regulations, would require further review by FDA.

If we can assist you further, please do not hesitate to contact us.

Sincerely yours,

Alan M. Rulis, Ph.D.
Acting Director
Office of Premarket Approval
Center for Food Safety and Applied Nutrition

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