Author: Wu Li, REACH24H Consulting Group, Hang Zhou

Since May 10, 2016, in Ecotech® Consumer Products, recycled plastic products polypropylene (PP) and High density polyethylene (HDPE) has received assessment of the US FDA, and 193 recycled plastic products have received US FDA’s No-objection letter, wherein PET products are 130, accounting for 67.35%; followed by polyethylene products, there are 15 products accounting for 0.07%, in addition to PC, PS, PP, HDPE, LDPE and so on.

US FDA has been actively encouraging for plastic packaging materials for recycling and reuse, but what can’t be ignored is that the recycled plastic applied to food packaging still remains many health and safety issues. Therefore, the FDA issued “Guidance for Industry: Use of Recycled Plastics in Food Packaging: Chemistry Considerations” to guide compliance of recycled plastics in food contact in 2006. Furthermore in the FDA official website, the introduction about Recycled Plastics in Food Packaging also gives inspection contents when recycled plastic is taken safety assessment, namely: 1) the contaminated residues after package use; 2) incorporation of the non-compliant food contact materials; 3) using auxiliaries which don’t satisfy specifications and requirements of food contact materials in recycling processes. Generally, what applicants need to prepare includes a complete description of the recycling processes, experiments for the removal of contaminant in the recovery process and illustrations of intended conditions of use for recycled plastic products. The assessment process is carried out case by case.

Apart from United States actively supports the use of recycled plastics, the EU has also formulated relevant laws and regulations ((EC) No 282/2008) and guidance to guide relevant enterprises the recovery and use of recycled plastics. But in China recycled plastics used in food packaging is much more conservative. However, there are some China, Japan and Taiwan companies making ​​a positive research on recycled plastic, and there are some products of eight Japanese companies receiving the FDA’s assessment of recycled plastic, and in Taiwan a company producing recycled plastic products has passed through the FDA evaluation.

For the use of recycled plastic in food packaging materials, the major food companies now make some active promotes, like Coca-Cola PET bottles for about 34% is recycled plastic, Heinz Group and other large multinational food companies have responded positively to the Coca-Cola company’s plans.  Plastic packaging as currently available and main type of packaging sector, will direct the waste water pollution, air pollution, solid waste pollution. In addition, with the increasing depletion of resources, recycled plastics bounds attract more and more attention. Therefore, recycling of plastic products for environmental protection, resource conservation, and sustainable development is very important. In the recycling process, it requires a reasonable level of recycled plastic sources, safety assessment through scientific methods to ensure the safety of recycled plastics.

REACH24H has rich experience in dealing with United States food contact materials (FDA /FCN / 21 CFR) and EU food contact materials (EU 10/2011/BfR) and can make custom-made compliance service for enterprises. If you have further questions, please consult

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