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No Objection Letter for Recycled Plastics #0046

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

See also Recycled Plastics in Food Packaging

January 17, 1997

Mr. Steven L. Stovall
Perstorp Xytec, Inc.
P.O. Box 99057
Tacoma, Washington 98499

Dear Mr. Stovall:

This is in response to your letter and attachments of March 8, 1995, regarding the proposed use of post-consumer recycled high density polyethylene (PCR-HDPE) from milk and water jugs to manufacture produce crates.

You have provided us with information regarding source control, and wash and manufacture procedures used to produce the PCR-HDPE. You state that the PCR-HDPE would be derived solely from reclaimed food-contact articles (e.g. milk and water jugs) and would be used to make crates to transport fruits and vegetables from the field and to hold the fruits and vegetables in cold storage for up to 10 months.

Based upon our review of the information you have provided and other data, we find that your proposed use of PCR-HDPE for manufacturing produce crates to hold fruits and vegetables at room temperature or below for up to 10 months is acceptable and will not require an amendment to the food additive regulations. This finding is based on the requirements that the PCR-HDPE is made from appropriately regulated food-contact articles and that any production aids and adjuvants (such as the colorants mentioned in your submission) used in the manufacture of the PCR-HDPE are also appropriately regulated.

Although we have concluded that your intended use of PCR-HDPE 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 we can be of any further help, please do not hesitate to contact us.

Sincerely yours, 

Eugene Coleman
Division of Petition Control, HFS-215
Center for Food Safety and Applied Nutrition

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