Does Chemically Recycled equal Recycled Materials according to BRCGS?

Hallo!

We produce flexible packaging and use various polymers.

Till now we used virgin polymers (granulate) only, and now we are thinking to use also some "recycled material".

The definition of "recycled material" according to BRCGS is quite strict: "Material that has been reprocessed from recovered material, including postconsumer or post-industrial waste ..."

The problem is that in our case the postconsumer waste was chemically recycled (split down to molecules) - i.e. it does have the same properties as a virgin materials (incl. food grade). 

It seems to me that in this case it would be not appropriate to change a bunch of documents and integrate this as a "recycled material" in the processes...

Did someone have an experience with such a situation?

Many thanks in advance!

I think your challenge is going to be that your recycled material falls squarely into the definition of recycled that is given in the Glossary section of the standard.

It seems entirely reasonable that part of the point of this focus in the standard is precisely to ensure that such materials are fully food-grade.

It might be fairly simple for your risk assessment / HARA purposes to demonstrate that the nature of the recycling process is such that you can treat the material as being equivalent to virgin polymers, but I still think you'd be expected to go through the process of documenting this.
You could always try asking your certification body for clarification, but I wouldn't be overly optimistic about it!

Thanks for your answer!

We were also thinking to handle it by a separate risk-assessment, just probably need some confirmation from the polymer-producer that the characteristics of the recycled material are absolutelly identical to the virgin material.

After that it depends of course on the auditor - how strict he wants to follow the definition from the Glossary...

Best Regards!

The most significant is that you found recycled polymer from chemical recycle process. From where? From who?  :ejut:  We search for such product everywhere but for now there are not sufficient quantities. Could you please tell us the type of recycled polymer and the country of origin? 

At the other hand, as mentioned in the standard, you should identify the possible risks from the recycled materials and how you prevent the contamination in each step of your production.  

Have a nice day!

Hello Polin,

as I wrote - we don't use the material at the moment, just thinking to use it in future and want to see what will be the additional work for BRC-adjustments.

You are fully right - there is no commercial ammount of ChemRec-materials on the market.

Our Purchasing department is also looking everywhere, but everything they find is a virgin material with some "impurities" of chemrec material - und already in this case the producer proudly calls it "partially recycled", wants more money for it and gives us additional headake adjusting documents for BRC...

Best regards.

I think if you were able to demonstrate that the recycled material came from a process approved to EC282/2008 the BRC would be happy even though most auditors would not be aware of it!

Changing documents to state that this was the case should be straightforward.

The bigger problem is proving to the various EU country tax authorities that your recycled material is in fact recycled. 

The UK and some other countries within the EU will tax heavily on anything less than a 30% recycled content.

 

The problem is that in our case the postconsumer waste was chemically recycled (split down to molecules) - i.e. it does have the same properties as a virgin materials (incl. food grade). 

I think if you were able to demonstrate that the recycled material came from a process approved to EC282/2008 the BRC would be happy even though most auditors would not be aware of it!

 

EC 282/2008; Article 1 1. (a):

 

recycled plastic materials and articles made with monomers and starting substances, derived from chemical depolymerization of plastic materials and articles;

I can see the synonyms in these red texts.