Food safety compliance of recycled plastic roll

hi there.
i wanna ask members here who are working in thermoforming plant.
we are using recycled plastics (mixed with virgin resin) in our extrusion process to produced plastic roll sheet for our thermoforming process.these scraps comes from our trimmings.
my question is, do we need to have it analyzed for hazardous chemical migration in food?
what is brc-iop regulations on using recycled materials??
comments will be appreciated
thanks

From a EU perspective you have to measure migration in food, be it virgin or recycled material.
You have to evaluate to risks that come with the recycling process, think about possible degradation of polymers, depends strongly on type of polymers.
Is there direct food contact possible or is the recycled material in a core layer in case of multi layer material?
If the recycled material is a mix of polymers?
Microbiological hazards are very low given the high temperatures and pressures during extrusion.
Contamination with foreign opbjects is more a processing issue than food safety.
BRC IoP states that recycled materials shall be appropriately protected against contamination hazards.
Traceability is some thing you have to sort out.

Have a nice day, Okido

the plastic container we make have direct food contact like cups, bowl,etc. material is PS.
are the auditors of brc-iop strictly require this EU regulations regardless of the country (e.g. asia) as one if the food safety parameters?

the plastic container we make have direct food contact like cups, bowl,etc. material is PS.
are the auditors of brc-iop strictly require this EU regulations regardless of the country (e.g. asia) as one if the food safety parameters?

No your products must comply with the regulations of your country and also the regulations of the country where your products are sold / used. If neither is the EU then the auditor shold not be looking for EU compliance.

Dear eden,

do we need to have it analyzed for hazardous chemical migration in food

With all due respect I believe yr original question implies that you were pretty sure of the answer.

I don't know how you control yr process but having occasionally seen some of the source providers of such, non-virgin, material, one would expect global regulations over such items. Not just a chemical safety problem, can also be disastrous IMEX when the receiver unknowingly uses it for demanding conditions, eg freezing.

Rgds / Charles.C

Some info I found on use of recycled plastics (not originating from your trimmings) which you might find useful.

**EU legislation on food contact materials
The web pages of the European Commission’s Health & Consumer Protection Directorate now contains an up-to-date register of valid applications for authorisation of recycling processes to produce recycled plastic materials and articles intended to come into contact with foods submitted to EFSA under article 13 of Regulation (EC) No 282/2008.

Rosie

**EU legislation on food contact materials
The web pages of the European Commission’s Health & Consumer Protection Directorate now contains an up-to-date register of valid applications for authorisation of recycling processes to produce recycled plastic materials and articles intended to come into contact with foods submitted to EFSA under article 13 of Regulation (EC) No 282/2008.

Link:
http://ec.europa.eu/...es_Art13_en.pdf

Recycled plastic materials intended to come into contact with foods are regulated at European level by a specific Regulation. This Regulation establishes particular provisions which supplement the existing legislation on food packaging. The recycled plastic used for the manufacture of materials and articles covered by this Regulation must be obtained from an authorised recycling process.

Hi Eden,

Our company is also into PET sheet extrusion and now starting on the thermoforming business. In our extrusion process we are reusing our side trims and qc rejected rolls which in common terms would be recycled materials. We are introducing the recycled materials in 10-30% blend with the virgin resin. Coupled with this we are also using Post Consumer Waste. How did we treat this in our hazard analysis?
For us to declare that the said product is safe and meets the Food Contact Plastic requirements we are sending our final product for testing in PIRA for both EC and USFDA directives etc... Test results are then used as proof to our customers.

Hope this will help.