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foodeng

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Posted 23 December 2020 - 05:04 AM

Does post consumer recycled materials ( LDPE film in mid layer) have food contact certificate?  If so which regulation and amendment is it related to?

 

 



jdpaul

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Posted 23 December 2020 - 05:48 PM

Just ask your supplier for a letter of guarantee 

 

https://www.fda.gov/...ood-contact-use

 

See specific example in link below:

 

https://www.ecfr.gov...SUBPART&ty=HTML

 

you can ask your supplier for this in writing asking that it complies with xx food contact packaging legislation in the company you are a producing 

 

Where are you producing?


Edited by jdpaul, 23 December 2020 - 05:54 PM.


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beautiophile

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Posted 24 December 2020 - 02:01 AM

Technically yes.

As long as the materials satisfy the requirements for food contact, they can be used. IMEX, that rarely happens. There are many reasons to avoid food application of post-consumer recycled plastic:

- Unknown usage history. Polymers mostly don't have a dense structure. They can absorb several substances in their lifetime. Nobody knows what the impurities are to make any accurate risk analyses.

- Degradation. The recycling process consists of grinding, melting, etc. Heat for melting can break weak organic chemical bonds in polymer chains. The shorter molecule chains are, the poorer mechanical properties the plastic performs (e.g. migration barrier). Beside that, broken bonds create byproducts (e.g. oligomers) which can be unwanted contaminants.

- Modification. Long exposure to air and heat in recycling process cause modifications on polymeric molecules such as oxidation with atmospheric oxygen. New functional groups can trap moisture water, catalyse other chemical reactions (e.g. producing carbonyl groups). So that the recycled plastic no is longer as safely neuter as the virgin one.

- Mixing-up. People usually assembly one plastic kind with other materials in a composite products. For example of a water bottle, the bottle body is made of PET, the cap of PP and label of paper. The separation (delamination in your case) and sorting are needed and are cumbersome jobs. The sorted plastic still contains a certain amount of other kinds.

- Tough validation. The above reasons leave so many considerations to verify food grading of recycled plastic; e.g. gathering usage information, checking material sources and compositions, frequent analyses of recycled materials, controlling of sorting process, controlling of contamination, hazard and risk analyses, etc.

It seems not to be economic or working ease.

AFAIK, post-consumer recycled plastics are always mixed with virgin one (max. 15-20%) to ensure their properties. I only find them in non-food usages, in case of PE, it's the inner net of a jacket, or a shampoo bottle, or lining of power wires.

 

Hope you can find results for your idea.



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Foodworker

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Posted 20 January 2021 - 10:59 AM

There are a number of considerations here.

 

The first is where the product will be sold as different countries have different rules.

 

If it is within the EU, the whole multi-layer film must comply with EU10/2011 and its various amendments. A food contact certificate is not required by law but it is very difficult to demonstrate compliance without one and your customers will almost certainly expect one.

 

A Declaration of compliance will also be required which goes further than a 'food contact certificate' as the certificate will only cover what parameters you ask the lab to test. The Declaration will need to state whether there are any chemicals used in the manufacture of the plastic for which there are Specific Migration Limits. There are other requirements to include in the Declaration and these are listed in Annex IV of EU10/2011.

 

With respect to the specific point about post recycled LDPE, any post recycled plastics used in a food contact material must have originated from a recycling process which in compliance with EC 282/2008. For this compliance, the recycling process and plant must be assessed and approved by the EU which goes much further than just testing a sample of plastic in the laboratory.

 

You should be able to obtain this information from your polymer suppliers if they comply.






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