Food: also safely packed in plastic recyclates

Recycled plastics are the basis for a whole series of new products. Recyclates boast the same characteristics as new plastics and are therefore just as suitable for use in many areas. However, food law provisions set limits on the use of recycled materials in direct contact with food.

There are no restrictions on the use of plastic recyclates for any non-food packaging. In principle, even materials and objects in direct contact with food can be manufactured from recycled plastics. However, it must be ensured at all times that an unwarrantable migration of substances into foodstuffs and an impairment of taste and smell are prevented – primarily with a view to excluding health hazards for consumers.

Use governed by Regulation

Since March 2008 this field has been governed by Regulation (EC) No. 282/2008 on recycled plastic materials and items intended to come into contact with foods. According to Dr. Lutz Wittenschläger (who among other things supports the expert network of Innoform GmbH), the effects of this Commission Regulation will only be felt in the near future. The Regulation is primarily aimed at reducing the complexity faced by recyclate users and implementing the waste management objectives of the Directive on Packaging (Directive 94/62/EC), which also governs the use of waste packaging by means of recycling. It applies to materials that contain recycled plastics and are intended to come into contact with foodstuffs. The requirements for the use of recycled plastics for food packaging were laid down not only for the material as such but also for its reclamation process.
As a result, the quality of the source material must be defined previously and monitored constantly: the source may only be derived from materials and objects originally intended for contact with foodstuffs. This applies to closed product cycles just as much as it does to collected materials, provided that their treatment process is proven to reduce impurities to a correspondingly harmless amount. Likewise, the quality of the recyclate must be defined and monitored in accordance with specified criteria and the conditions for use stipulated.

Recyclates produced by chemical depolymerisation of waste plastics or manufactured directly from the production rejects and/or processing residues of plastics intended for contact with foodstuffs at the production site, are not covered by the Regulation. Here legislators assume that recyclates are free from impurities to the required degree. This also holds true for recyclates used behind a functional plastic barrier.

First EU approvals granted

If a company intends to run a recycling operation for manufacturing plastic recyclates intended for contact with food, it must apply for a relevant approval from the European Food Safety Agency (EFSA). Labelling of materials and items made of recycled plastics and/or containing portions thereof is not mandatory. The decision of the European Commission on the approval is to be published in the Official Journal of the European Union and state any limitations on the use of the recyclate. According to Wittenschläger, no approvals had been issued until the beginning of the year. The first approved processes are beginning to appear on the website of the European Commission now. This is also where a current listing of the applications filed so far can be found: (http://ec.europa.eu/food/food/chemicalsafety/foodcontact/documents_en.htm).

Price benefit and eco plus

There are transition periods for recycled plastics produced before the Regulation entered into force and for the products made thereof. Wittenschläger arrives at the conclusion that soon it will be possible for food packaging to also be manufactured using plastic recyclates with legal certainty within the very strict legal framework of the Regulation – without compromising on the suitability of the recycled materials. For packaging producers he sees possible price benefits plus the added benefit of being able to focus even more on the ecological component of one’s products – a USP that is certain to be of growing importance.