Recycled plastic in food contact materials?

Recycling of plastic materials and articles intended to come into contact with foods
Recycled plastic with the intended use as food-contact material (FCM) needs to be recycled at a high safety level. EFSA defined different requirements for recycling processes depending on whether they are based on a Suitable technology or developed as a Novel technology [1].
For FDA, a uniform approach is recommended to show that the recycled material is safe for use in contact with food [2]. Both organizations consider a challenge test an important element of the safety evaluation.

Recycling of non-PET: Novel technologies (EFSA) EFSA considers every technology not listed as a Suitable technology a Novel technology. A Novel technology needs to be notified before recycled FCM can be placed onto the market and regular monitoring should be conducted. After at least a two-year period, the developer can request the assessment of the Novel technology.

Triskelion services for Novel technologies • Design of a testing strategy When notifying a Novel technology, the developer needs to show that the produced material is safe for use as FCM. With significant experience in petitioning and the multidisciplinary team of chemical engineers, mechanical engineering, analytical chemists and food scientist, our project managers advise and support you for the studies that should be conducted. • Monitoring Triskelion offers different analytical screening methodologies to target all relevant contamination in the input materials and the residual contaminant levels in the final materials and articles. Special sample preparation methods can increase sensitivity. The transfer of contaminants to food can be determined in silico with modelling software or in migration experiments. • Challenge testing The multidisciplinary team of project managers has the perfect competence mix to design the challenge test (select the surrogates, contamination procedure and analytical methods) for the Novel technology you are developing.

References:
[1] Commission Regulation (EU) 2022/1616 of 15 September 2022 on recycled plastic materials and articles intended to come into contact with foods, and repealing Regulation (EC) No 282/2008
[2] Center for Food Safety and Applied Nutrition, Office of Food Additive Safety: Guidance for Industry: Use of Recycled Plastics in Food Packaging (Chemistry Considerations), July 2021.
[3] EFSA Panel on food contact materials, enzymes, flavourings and processing aids (CEF); Scientific Opinion on the criteria to be used for safety evaluation of a mechanical recycling process to produce recycled PET intended to be used for manufacture of materials and articles in contact with food. EFSA Journal 2011;9(7):2184.