As the emphasis on creating recycling-ready packaging grows, commercial and legislative interests are increasing pressure on manufacturers to use more post-consumer recycled (PCR) material. When compared with virgin materials, it is unsurprising that mechanically recycled polyolefin PCR resins almost always display lower quality at a higher cost. Quality issues include gel, color and odor deficiencies that affect functional performance as well as aesthetic properties. Less well known is that the current food contact suitability criteria that guide the use of recycled plastics in food packaging restrict their use. Typical challenges for recyclates include traceability, overcoming potential misuse during prior handling and separation of food contact compliant from non-compliant waste. In the EU and the US, not only is the uniformity and security of the PCR source considered, but the recycling process itself must be evaluated for its ability to consistently supply a safe, clean product. Fundamentally, it is expected that the PCR resin must be of suitable purity to meet all of the food safety specifications of a virgin polymer.<br/><br/>One of the most complicated technical and regulatory issues facing mechanical plastic recyclers producing food contact materials is their obligation to ensure traceability of all input materials. Since the input materials for PCR are always uncontrolled at some point, management of contamination by not intentionally added substances (NIAS) and substances of very high concern (SVHC) is challenging. Although FDA is satisfied that PET recycling processes are capable of removing NIAS, polyolefin recovery processes must continue to pass rigorous surrogate contaminant testing to demonstrate suitable purity is achievable. These constraints limit commercial supply and make broad-based PCR addition to food packaging difficult. While it is important for the food packaging industry to increase its use of PCR polymers, guaranteeing that they are food safe remains challenging. Innovation is needed to close the supply/demand gap for food safe PCR resins.

Food safety considerations regarding expanded PCR use in food packaging

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