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CFSAN/Office of Food Additive Safety
December 2008
Recycled Plastics in Food Packaging |
There is an emphasis throughout the United States on increasing the uses of recycled materials, including plastic. FDA is involved when industry collects used polymeric materials (usually food containers) and proposes to recycle these materials to make new food containers. FDA's main safety concerns with the use of recycled plastic materials in food-contact articles are: 1) that contaminants from the post consumer material may appear in the final food-contact product made from the recycled material, 2) that recycled post-consumer material not regulated for food-contact use may be incorporated into food-contact packaging, and 3) that adjuvants in the recycled plastic may not comply with the regulations for food-contact use. Currently, to address these concerns, FDA considers each proposed use of recycled plastic on a case-by-case basis and issues informal advice as to whether the recycling process is expected to produce plastic suitable for food-contact applications. FDA has prepared a document entitled Guidance for Industry - Use of Recycled Plastics in Food Packaging: Chemistry Considerations that will assist manufacturers of food packaging in evaluating processes for recycling plastic into food packaging.
If a manufacturer would like FDA to consider the use of recycled plastic for a food-contact application, the following information should to be submitted:
The table below is a list of submissions for which FDA issued a favorable opinion on the suitability of a specific process for producing post-consumer recycled (PCR) plastic to be used in the manufacturing of food-contact articles. The list includes the date of our "no objection letter" (NOL), the company that made the request, the subject plastic, whether the recycling process is physical or chemical, and limitations on the conditions of use for the recycled plastic. Because the agency is currently developing a formal policy on the use of recycled plastics in contact with food, the decisions set forth in in these opinion letters may need to be modified due to future deliberations on this matter.
For each entry in the table below, there is a hyperlink from the date of the NOL to a redacted copy (in PDF format) of the NOL issued by the FDA.
The Adobe Acrobat reader for PDF files can be downloaded from the Adobe Acrobat Web Site at no charge. For additional help opening and viewing PDF files please consult CFSAN's General Help for Accessing Files page.
Questions pertaining to the use of recycled plastics in food packaging should be directed to the Office of Food Additive Safety ().
Additional Contact Information
No. | Date of NOL | Company | Polymer | Recycling Process | Use Limitations |
---|---|---|---|---|---|
1 | 2/21/90 (letter in PDF) |
Dolco Packaging Co. | Polystyrene | Physical | Whole egg cartons |
2 | 6/6/90 (letter in PDF) |
Covington & Burling | Recycled polymers in general | Not specified | Grocery bags |
3 | 1/9/91 (letter in PDF) |
Keller & Heckman on behalf of Hoechst Celanese | PET | Chemical - Regenerated dimethyl terephthalate from depolymerized PET bottles | PET food-contact articles |
4 | 3/13/91 (letter in PDF) |
Lewisystems | Polyethylene or Polypropylene | Physical | Harvesting crates for fresh fruits and vegetables |
5 | 4/24/91 (letter in PDF) |
Larkin, Hoffman, Daly & Lindgren, Ltd., on behalf of Ultra Pac, Inc. | PET | Physical | Baskets for fresh fruits and vegetables |
6 | 5/23/91 (letter in PDF) |
Landfill Alternatives, Inc. | Polystyrene | Physical | Whole egg cartons |
7 | 8/20/91 (letter in PDF) |
Keller & Heckman on behalf of Eastman Chemical Co. | PET | Chemical - Regenerated ethylene glycol and dimethyl terephthalate from depolymerized PET bottles | PET food packaging |
8 | 9/3/91 (letter in PDF) |
Larkin, Hoffman, Daly & Lindgren, Ltd., on behalf of Ultra Pac, Inc. | PET | Physical | Fresh fruit and vegetable trays |
9 | 12/6/91 (letter in PDF) |
Goodyear Tire & Rubber Company | PET | Chemical - PET oligomers from depolymerized PET bottles | PET food packaging |
10 | 3/10/92 (letter in PDF) |
Coca-Cola Company | PET | Ethylene glycol as a by-product from manufacturing food grade PET | PET food-contact resin |
11 | 8/21/92 (letter in PDF) |
Bullwinkle Partners, Ltd. on behalf of Repak | PET | Physical | Fresh fruit and vegetable baskets and trilaminate clamshell food-contact containers for short-term contact (< 2 weeks) at room temperature or below (interior layer of post-consumer recycled (PCR) PET is separated from food by at least a 1 mil thick layer of virgin, food-grade PET) |
12 | 8/25/92 (letter in PDF) |
Larkin, Hoffman, Daly & Lindgren, Ltd., on behalf of Ultra Pac, Inc. | PET | Physical | Nonfood-contact layer in containers for short term storage of food (< 2 weeks) at room temperature or below. The interior layer of PCR PET is separated from food by a layer of virgin, food grade PET 1 mil thick. |
13 | 10/14/92 (letter in PDF) |
Keller & Heckman on behalf of DuPont Co. | PET | Chemical - Regenerated ethylene glycol and dimethyl terephthalate from depolymerized post-consumer PET. | PET food-contact articles |
14 | 11/19/92 (letter in PDF) |
Lewisystems | Polyethylene and Polypropylene | Physical | Containers for storing refrigerated poultry, red meat, and seafood |
15 | 12/31/92 (letter in PDF) |
De Ster U.S. Holding Corp. | Polystyrene | Physical | Nonfood-contact layer of polystyrene airline snack containers used for storing foods for a short period of time (< 2 weeks) and at room temperature or below, providing PCR polystyrene is separated from food by a layer of virgin, food grade polystyrene 1 mil thick. |
16 | 3/1/93 (letter in PDF) |
Scientific Certification Systems on behalf of Dolco Packaging Corp. | Polystyrene | Physical | For use in making trays for holding refrigerated meat, providing the PCR polystyrene was previously used for food-contact applications and there is strict source control. |
17 | 4/14/93 (letter in PDF) |
Keller & Heckman on behalf of Continental PET Technologies, Inc. | PET | Physical | Non-food contact layer in soft drink bottles at room temperature or below, providing recycled PET is separated from food by a layer of virgin, food grade PET 1 mil thick. |
18 | 6/30/93 (letter in PDF) |
Keller & Heckman on behalf of Novacor Chemical, Inc. | Polystyrene | Physical | For manufacturing plates, cutlery, trays, cups, containers, and lids for restaurants, providing there is strict source control of PCR polystyrene that was previously used for food-contact applications. |
19 | 7/1/93 (letter in PDF) |
Dolco Packaging Corp. | Polystyrene | Physical | Fruit and vegetable containers, food-service clamshells, and poultry trays, providing there is strict source control. |
20 | 10/21/93 (letter in PDF) |
Fabri-Kal Corp. | Polystyrene (crystal and rubber modified) | Physical | Nonfood-contact layer of polystyrene cold drink cups, lids, produce trays, portion cups, and deli food containers, providing PCR polystyrene is from strict sources and is separated from food by a layer of virgin, food grade polystyrene 1 mil thick. Articles are for short term contact (12 days) with food at room temperature or below. |
21 | 12/15/93 (letter in PDF) |
Keller & Heckman | PET | Physical | Nonfood-contact layer in packaging for short term storage of food at room temperature or below. The interior layer of PCR PET is separated from food by 1 mil thick layer of virgin, food grade PET. |
22 | 12/20/93 (letter in PDF) |
Coca-Cola Co. | PET | Ethylene glycol as a by-product from manufacturing food grade PET | Food-contact PET |
23 | 5/5/94 (letter in PDF) |
Keller & Heckman on behalf of Continental PET Technologies, Inc. | PET | Physcial | Non-food contact layer in PET articles for holding aqueous, acidic, and low-alcoholic foods under Condition of Use C (Hot filled or pasteurized above 150 °F) and below, providing recycled PET is separated from food by a layer of virgin, food grade PET 1 mil thick, and the food-contact article is used for storage periods not to exceed one year. |
24 | 6/3/94 (letter in PDF) |
Morgan, Lewis, & Bockius on behalf of KAMA Corp. | PET | Physical | Containers for storing fresh fruits and vegetables at room temperature or below. |
25 | 8/3/94 (letter in PDF) |
Keller & Heckman on behalf of Creative Forming, Inc. | PET | Physical | Containers for storing fresh fruits and vegetables at room temperature or below, providing PCR PET comes from food-contact articles. |
26 | 8/24/94 (letter in PDF) |
Keller & Heckman on behalf of Johnson Controls, Inc. | PET | Physical | Food containers in contact with all types of food under Condition of Use A or below. |
27 | 11/16/94 (letter in PDF) |
FP Corp. | Polystyrene | Physical | Nonfood-contact layer of polystyrene containers for short term contact (6-8 hours) with food at 50 °F or below, providing post-consumer polystyrene is separated from food by a layer of virgin, food grade polystyrene 1 mil thick. |
28 | 12/5/94 (letter in PDF) |
Keller & Heckman on behalf of Wellman, Inc. | PET | Physical | Containers for storing fresh fruits and vegetables at room temperature or below, providing PCR PET comes from articles used for food-contact applications. |
29 | 2/22/95 (letter in PDF) |
Health Products International | High density polyethylene (HDPE) | Physical | Nonfood contact layer of a bottle for packaging dry dietary supplements, providing PCR HDPE is separated from food by a layer of virgin, food grade HDPE 12 mils thick. |
30 | 2/28/95 (letter in PDF) |
Keller & Heckman on behalf of Continental PET Technologies, Inc. | PET | Physical | Corrected our letter of 5/5/94 by removing restrictions on conditions of use and time of storage. |
31 | 3/20/95 (letter in PDF) |
Flagstar | Polystyrene | Physical | Nonfood-contact layer of polystyrene clam shells and other food service containers, providing PCR polystyrene is separated from food by a layer of virgin, food grade polystyrene 1 mil thick, the PCR polystyrene was previously used for food-contact applications and there is strict source control, and the containers are limited to contact with hot and cold foods for only a few minutes. |
32 | 5/11/95 (letter in PDF) |
Keller & Heckman on behalf of Wellman, Inc. | PET | Physical | Nonfood contact layer in containers for limited food contact applications for short term storage periods at room temperature or below, providing recycled PET is separated from food by a layer of virgin, food grade PET 1 mil thick, and the PCR is from reclaimed food-contact articles. |
33 | 7/17/95 (letter in PDF) |
Scientific Certification Systems on behalf of ELM Packaging Co. | Polystyrene | Physical | Nonfood-contact layer of polystyrene containers, providing PCR polystyrene is separated from food by a layer of food grade virgin polystyrene 1 mil thick, the PCR polystyrene was previously used for food-contact applications and there is strict source control, and the containers are limited for "fast food" service applications to contact hot and cold foods (i.e., those involving refrigerated or room temperatures or, if higher temperatures are involved, contact is limited to very short time frames). |
34 | 7/3/95 (letter in PDF) |
FP Corp. | Polystyrene | Physical | Nonfood-contact layer of polystyrene containers for short term contact (2-3 days) with all food types at 50 °F or below, providing PCR polystyrene is separated from food by a layer of virgin, food grade polystyrene 1 mil thick. |
35 | 8/29/95 (letter in PDF) |
Keller & Heckman on behalf of Wellman, Inc. | PET | Physical | Nonfood contact layer in containers for limited food contact applications, providing PCR PET is separated from food by a layer of virgin, food grade PET 1 mil thick, the food-contact article is used for short term storage periods at room temperature or below, and the amount of PCR PET from nonfood applications does not exceed 0.6%. |
36 | 9/25/95 (letter in PDF) |
Union Carbide Corp. | HDPE | Physical | Nonfood contact layer in a 2 or 3 layer bottle in contact with dry food with no free surface fat at room temperature or below, providing that the PCR HDPE is separated from food by a layer of virgin, food grade HDPE 4 mil thick, and the PCR HDPE was previously used for food-contact applications. |
37 | 10/12/95 (letter in PDF) |
Keller & Heckman on behalf of Hoechst Celanese | PET | Chemical (glycolysis) | PET Food-contact articles |
38 | 11/2/95 (letter in PDF) |
Larkin, Hoffman, Daly & Lindgren, Ltd., on behalf of Ultra Pac, Inc. | Crystallized PET (C-PET) | Physical | C-PET cake pans produced from old commercial C-PET cake pans, providing there is strict source control. |
39 | 3/12/96 (letter in PDF) |
Keller & Heckman on behalf of Wellman, Inc. | PET | Chemical (glycolysis) | For use in contact with aqueous foods under Condition of Use C or less severe conditions, and fatty foods under Condition of Use D or less severe conditions. |
40 | 3/13/96 (letter in PDF) |
Keller & Heckman on behalf of Wellman, Inc. | PET | Physical | For use in contact with aqueous and acidic foods under Condition of Use C or less severe conditions, and fatty and alcoholic foods under Condition of Use D or less severe conditions, providing PCR PET is from food containers collected through a bottle deposit system. |
41 | 4/4/96 (letter in PDF) |
Scientific Certification Systems on behalf of Enviroplastics | HDPE | Physical | Produce bags from recycled milk jugs |
42 | 5/1/96 (letter in PDF) |
Innovations in PET Pty Ltd. | PET | Chemical (glycolysis) | PET food-contact articles, provided resulting PET complies with 21 CFR 177.1630. |
43 | 5/2/96 (letter in PDF) |
Keller & Heckman on behalf of Wellman, Inc. | PET | Physical | For use in contact with dry, aqueous, and acidic foods under Condition of Use C or less severe conditions, and fatty and alcoholic foods under Condition of Use D or less severe conditions, providing PCR PET is from food containers collected through a bottle deposit system and recycled PET complies with 21 CFR 177.1630. |
44 | 7/25/96 (letter in PDF) |
Keller & Heckman on behalf of Plastipak Packaging, Inc. | PET | Physical | Non-food contact layer in PET containers for holding foods of all types under Condition of Use C (Hot filled or pasteurized above 150 °F) and below, providing recycled PET is separated from food by a layer of virgin, food grade PET 1 mil thick. |
45 | 10/18/96 (letter in PDF) |
Keller & Heckman on behalf of Eastman Chemical Co. | PEN | Chemical - Regenerated dimethylnapthalene dicarboxylate and ethylene glycol from depolymerized PCR poly(oxy-1,2 - ethanediyloxycarbonyl - 2,6-naphthalenediylcarbonyl (PEN) resins using a methanolysis process. | PEN resins for food-contact applications, provided resulting PEN complies with 21 CFR 177.1637. |
46 | 1/17/97 (letter in PDF) |
Perstorp Xytec, Inc. | HDPE | Physical | Crates for holding fruits and vegetables at room temperature or below for up to 10 months, providing PCR HDPE is from food-contact articles. |
47 | 1/28/97 (letter in PDF) |
Health Products International | HDPE | Physical | Bottles for packaging dry dietary supplements, providing PCR HDPE is obtained from milk jugs. |
48 | 6/6/97 (letter in PDF) |
Keller & Heckman on behalf of Wellman, Inc. | PET | Physical | For use in contact with dry and aqueous foods under Condition of Use C or less severe conditions, and fatty foods under Condition of Use D or less severe conditions, providing PCR PET is from food containers collected through a bottle deposit system, and recycled PET complies with 21 CFR 177.1630. |
49 | 6/6/97 (letter in PDF) |
Keller & Heckman on behalf of Eastman Chemical Co. | PET | Chemical (glycolysis) | PET resin for food-contact applications, provided resulting PET complies with 21 CFR 177.1630. |
50 | 12/18/97 (letter in PDF) |
Scientific Certification Systems on behalf of Enviroplastics | HDPE | Physical | Berry baskets and produce trays, provided PCR HDPE is obtained from milk jugs. |
51 | 1/5/98 (letter in PDF) |
Keller & Heckman on behalf of Crown Cork and Seal Co., Inc. | PET | Physical | Articles for contact with aqueous, acidic, and low alcoholic foods (15% or less) under Condition of Use C or less severe conditions. |
52 | 1/16/98 (letter in PDF) |
Union Carbide Corp. | HDPE | Physical | For packaging aqueous and/or acidic food under Conditions of Use C through H, providing PCR HDPE is from bottles used in food-contact applications. |
53 | 7/21/98 (letter in PDF) |
Keller & Heckman on behalf of Continental PET Technologies, Inc. | PET | Physical | Non-food contact layer in PET bottles for holding high-alcoholic and fatty foods under Condition of Use D (Hot filled or pasteurized below 150 °F) and below, providing recycled PET is separated from food by a layer of virgin, food grade PET 1 mil thick, and the food-contact article is used for storage periods not to exceed one year. |
54 | 10/2/98 (letter in PDF) |
Pure Tech Plastics, Inc. | PET | Physical | Articles for contact with aqueous, acidic, low alcoholic (8% or less), and dry foods at room temperature (120 °F) or below. |
55 | 12/29/98 (letter in PDF) |
Keller & Heckman on behalf of Clean Tech, Inc. | PET | Physical | Articles for contact with all types of food under Condition of Use A (High temperature heat -sterilized (e.g., over 212 °F)) and less severe conditions. |
56 | 12/29/98 (letter in PDF) |
Dolco Packaging Corp. | Polystyrene | Physical | Fruit and vegetable containers, food-service clamshells, and meat and poultry trays, providing the recycled polystyrene is obtained from pre-consumer sources and there is strict source control. |
57 | 4/13/99 (letter) |
Fraunhofer Institut Verfahrenstechnik und Verpackung on behalf of OHL Apparatebau & Verfahrenstechnik GmbH | PET | Physical | Articles for contact with all types of food at room temperature (120 °F) or below, providing PCR PET comes from food-contact articles, and the recycled PET complies with 21 CFR 177.1630. |
58 | 8/10/99 (letter in PDF) |
Keller & Heckman on behalf of Phoenix Technologies, L.P. | PET | Physical | Articles for contact with dry (no surface fat or oil), aqueous, acidic, and low-alcohol (<15%) foods at room temperature and below, provided the pcr pet comes from containers previously used for food and non-food applications (excluding industrial pet containers) obtained from deposit and curbside recycling programs, and the recycled pet complies with 21 177.1630. |
59 | 8/10/99 (letter in PDF) |
Keller & Heckman on behalf of Phoenix Technologies, L.P. | PET | Physical | Articles for contact with dry (no surface fat or oil), aqueous, acidic, and low-alcohol (<15%) foods at room temperature and below, provided the pcr pet comes from containers previously used for food and non-food applications (excluding industrial pet containers) obtained from deposit and curbside recycling programs, and the recycled pet complies with 21 177.1630. |
60 | 2/1/00 (letter) |
Keller & Heckman on behalf of United Resource Recovery Corp. | PET | Physical | Articles for contact with dry (no surface fat or oil), aqueous, acidic, and low-alcohol (<15%) foods at room temperature and below, provided the pcr pet comes from containers previously used for food and non-food applications (excluding industrial pet containers) obtained from deposit and curbside recycling programs, and the pcr pet complies with 21 177.1630 or 177.1315. |
61 | 2/3/00 (letter) |
Morgan, Lewis & Bockius on behalf of Ivex Packaging Corp. | PET | Physical | Nonfood-contact layer in packaging for applications at room temperature or below. The interior layer of PCR PET is separated from food by 1 mil thick layer of virgin, food grade PET. |
62 | 8/1/00 (letter) |
Polystyrene Recycling Company of America | Polystyrene | Physical | For manufacturing trays for holding refrigerated meat/poultry, fruit/vegetable containers and food-service clam shells, providing the PCR polystyrene was previously used for food-contact applications and there is strict source control. Additionally, the PCR polystyrene may be used as the blending component of a nonfood-contact layer of polystyrene containers, plates, and cutlery, providing PCR polystyrene is separated from food by a layer of virgin, food grade polystyrene 1 mil thick, the PCR polystyrene was previously used for food-contact applications and there is strict source control, and the articles are limited for "fast food" service applications to contact hot and cold foods (i.e., those involving refrigerated or room temperatures or, if higher temperatures are involved, contact is limited to very short time frames). |
63 | 8/23/00 (letter) |
Keller & Heckman on behalf of Eastman Chemical Co. | PET | Chemical (glycolysis/methanolysis) | Articles for contact with all types of food, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630 or 177.1315. |
64 | 11/17/00 (letter) |
Fraunhofer Institute for Process Engineering and Packaging on behalf of EREMA Plastic Recycling Systems | PET | Physical | Articles for contact with all types of food at room temperature and below, provided the PCR PET comes from containers previously used for food applications obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630. |
65 | 4/20/01 (letter) |
Keller and Heckman on behalf of Plastic Technologies, Inc. | PET | Physical | Articles for contact with dry (no surface fat or oil), aqueous, acidic, and low-alcohol (<15%) foods under conditions of use B-H, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial pet containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630. |
66 | 6/1/01 (letter) |
Visy Plastics Pty Ltd. | PET | Physical | Articles for contact with dry (no surface fat or oil), aqueous, acidic, and low-alcohol (<15%) foods at room temperature and below, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial pet containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630. |
67 | 6/7/01 (letter) |
Fraunhofer Institute for Process Engineering and Packaging on behalf of EREMA Plastic Recycling Systems | PET | Physical | Articles for contact with all types of food at room temperature and below, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630. |
68 | 6/13/01 (letter) |
Fraunhofer Institute for Process Engineering and Packaging on behalf of Buhler AG. | PET | Physical | Articles for contact with with all types of food under Condition of Use C and less severe conditions, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630. |
69 | 8/28/01 (letter) |
Evergreen Partnering Group Inc. | Polystyrene | Physical | For manufacturing food-contact articles to be used by cafeterias in institutions such as colleges, schools, hospitals, and jails, providing there is strict source control of PCR polystyrene that was previously used for food-contact applications. |
70 | 9/20/01 (letter) |
Center for Regulatory Services on behalf of AIES Company, Ltd. | PET | Chemical (glycolysis) | PET food-contact articles |
71 | 12/18/01 (letter) |
Keller & Heckman on behalf of NanYa Plastics Corp. | PET | Chemical (glycolysis) | PET food-contact articles |
72 | 12/21/01 (letter) |
Keller & Heckman on behalf of Teijin Limited | PET | Chemical (methanolysis) | PET food-contact articles |
73 | 6/26/02 (letter) |
Signum | PET | Physical | Nonfood-contact layer in packaging for applications at room temperature (120 °F) or below. The interior layer of PCR PET is separated from food by 1 mil thick layer of virgin, food grade PET. |
74 | 1/28/03 (letter) |
Recipet and Typack | PET | Physical | Containers (e.g., clamshells, trays, and baskets) for short term storage (up to several weeks) of fresh fruits and vegetables at room temperature (120 °F) or below, provided the PCR PET comes from PET soda and juice bottles obtained from deposit and curbside recycling programs. |
75 | 1/28/03 (letter) |
Keller & Heckman on behalf of Wellman, Inc. | PET | Physical | For use in contact with dry, aqueous, and acidic foods under Condition of Use C or less severe conditions, and fatty and alcoholic foods under Condition of Use D or less severe conditions, provided the PCR PET comes from containers obtained from deposit and curbside recycling programs, and the recycled PET complies with 21 CFR 177.1630 and any other applicable regulations. |
76 | 2/10/03 (letter) |
Fraunhofer Institute for Process Engineering and Packaging on behalf of EREMA GmbH | PET | Physical | Articles for contact with all types of food for hot fill applications above 150 °F or less severe conditions, provided the PCR PET comes from containers previously used for food and/or non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630 and any other applicable regulations. |
77 | 2/10/03 (letter) |
Fraunhofer Institute for Process Engineering and Packaging on behalf of AMCOR Twinpak - North America Inc. | PET | Physical | Articles for contact with all types of food for hot fill applications above 150 °F or less severe conditions, provided the PCR PET comes from containers previously used for food or non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630 and any other applicable regulations. |
78 | 2/21/03 (letter) |
Keller & Heckman on behalf of Mitsubishi | PET | Chemical (methanolysis) | PET food-contact articles |
79 | 3/17/03 (letter) |
Fraunhofer Institute for Process Engineering and Packaging on behalf of OHL Apparatebau & Verfahrenstechnik GmbH | PET | Physical | Articles for contact with all types of food at room temperature (120 °F) and below, provided the PCR PET comes from containers previously used for food and/or non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630 and any other applicable regulations. |
80 | 3/26/03 (letter) |
Fraunhofer Institute for Process Engineering and Packaging on behalf of OHL Apparatebau & Verfahrenstechnik GmbH | PET | Chemical (glycolysis) | PET food-contact articles |
81 | 5/22/03 (letter) |
Roychem | PET | Chemical (glycolysis) | PET food-contact articles |
82 | 6/30/03 (letter) |
Fraunhofer Institute for Process Engineering and Packaging on behalf of OHL Apparatebau & Verfahrenstechnik GmbH | PET | Physical | Articles for contact with food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630. |
83 | 8/14/03 (letter) |
Keller & Heckman on behalf of Pure Tech Plastics | PET | Physical | Articles for contact with food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630. |
84 | 11/18/2003 (letter) |
Keller & Heckman on behalf of Plastic Technologies, Inc | PET | Physical | Articles for contact with food under Conditions of Use B through H, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630. |
85 | 12/30/2003 (letter) |
Fraunhofer-Institut für Verfahrenstechnik und Verpackung on behalf of ERMA GmbH | PET | Physical | Articles for contact with food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630. |
86 | 6/4/2004 (letter) |
OFI Technologie & Innovation GmbH on behalf of STARLINGER & Co. GmbH | PET | Physical | Articles for contact with food under Conditions of Use E through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630. |
87 | 6/4/2004 (letter) |
Fraunhofer-Institut für Verfahrenstechnik und Verpackung on behalf of Se.Ri.Plast. s.r.l., | PET | Physical | Articles for contact with shell eggs and fresh fruit and vegetables that would be peeled or washed before consumption under Conditions of Use E through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630. |
88 | 7/9/2004 (letter) |
Fraunhofer-Institut für Verfahrenstechnik und Verpackung on behalf of Sipa s.p.a. | Urethane-Acrylate | Physical | Use as nonfood-contact layer of PET bottles will not effect recyclability of such bottles by conventional or "superclean" methods. |
89 | 7/13/2004 (letter) |
Keller & Heckman on behalf of Pure Tech Plastics | PET | Physical | Articles for contact with food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630. |
90 | 9/9/2004 (letter) |
Visy Industries | PET | Physical | Articles for contact with food under Conditions of Use E through G, as well as for contact with dry (no surface fat or oil), aqueous, acidic, and low-alcohol content foods under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630. |
91 | 12/29/2004 (letter) |
SIGNUM | PET | Physical | Nonfood-contact layer in packaging for applications at room temperature (120 °F) or below, provided the PCR-PET comes exclusively from containers previously used for food and the PCR PET is separated from food by 1 mil thick layer of virgin, food grade PET. |
92 | 1/25/2005 (letter) |
Keller & Heckman on behalf of Mitsui Chemicals Inc | PET | Physical | Articles for contact with aqueous, acidic, and low-alcohol content foods under conditions of use B through H provided the PCR PET comes exclusively from containers previously used for food obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630. |
93 | 2/17/2005 (letter) |
Keller & Heckman on behalf of United Resource and Recovery Corporation | PET | Physical | Articles for contact with food under Conditions of Use B through H, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630. |
94 | 7/20/2005 (letter) |
Keller & Heckman on behalf of Sidel Inc | Hydrogenated Carbon | Food contact layer applied at a minimum thickness of 0.065 microns for use with PET resin consisting of up to 50 % PCR PET under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs. | |
95 | 3/15/2005 (letter) |
Keller & Heckman on behalf of United Resource Recovery Company (URRC) | PET | Physical | Articles for contact with all types of food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications, and the PCR PET complies with 21 CFR 177.1630 and 177.1315. |
96 | 5/25/2005 (letter) |
Keller & Heckman on behalf of Eastman Chemical Co. | PET | Chemical (glycolysis) | PET Food-contact articles. |
97 | 10/26/2005 (letter) |
Keller & Heckman on behalf of Toyo Seikan Kaisha, Ltd. | PET | Physical | Nonfood-contact layer in packaging for applications under Condition of Use C and below, provided the PCR PET is separated from food by ≥ 2 mil thick layer of virgin, food grade PET, and the PCR PET complies with 21 CFR 177.1630. |
98 | 1/13/2006 (letter) |
Keller & Heckman on behalf of Plastic Technologies, Inc. (PTI) | PET | Physical | Articles consisting of up to 50% PCR PET for contact with all types of food under Conditions of Use B through H. |
99 | 4/27/2006 (letter) |
Packaging Development Resources (PDR) | Polystyrene | Physical | For manufacturing food-contact articles to be used in fast-food and similar restaurants, provided the PCR polystyrene was previously used for food-contact applications and there is strict source control. |
100 | 6/15/2006 (letter) |
Fraunhofer-Institut Verfahrenstechnik und Verpackung on behalf of SIPA SpA | PET | Physical | Articles for contact with all types of food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications. |
101 | 10/10/2006 (letter) |
Fraunhofer-Institut Verfahrenstechnik und Verpackung on behalf of Rethmann Plano | PET | Physical | Articles for contact with food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications. |
102 | 11/28/2006 (letter) |
Fraunhofer-Institut Verfahrenstechnik und Verpackung on behalf of KRONES AG | PET | Physical | Articles for contact with food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications. |
103 | 12/6/2006 (letter) |
Fraunhofer-Institut Verfahrenstechnik und Verpackung on behalf of Waste and Resource Action Program (WRAP) | PET | Physical | Articles for contact with food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications. |
104 | 12/26/2006 (letter) |
Fraunhofer-Institut Verfahrenstechnik und Verpackung on behalf of UOP | PET | Physical | Articles for contact with food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications. |
105 | 12/26/2006 (letter) |
Merlin Plastics Alberta, Inc. | PET | Physical | Articles (e.g., clamshells) for contact with raw fruits and vegetables and shell eggs, for short periods of time at room temperature or below (e.g. Conditions of Use E through G), provided the PCR PET comes from food and beverage containers collected through a bottle deposit system (excluding non-food PET containers and industrial PET containers). |
106 | 1/31/2007 (letter) |
Fraunhofer-Institut für Verfahrenstechnik und Verpackung on behalf of SIPA s.p.a. | Epoxy and acrylic-based polymers | Physical | Use as nonfood-contact layer of PET bottles will not effect recyclability of such bottles by conventional or "super clean" processes. |
107 | 1/31/2007 (letter) |
Fraunhofer-Institut für Verfahrenstechnik und Verpackung on behalf of Plastlac Srl | Acrylic polymers | Physical | Use as nonfood-contact layer of PET bottles will not effect recyclability of such bottles by conventional or "super clean" processes. |
108 | 4/20/2007 (letter) |
Fraunhofer Institut Verfahrenstechnik und Verpackung on behalf of Waste and Resource Action Program (WRAP) | HDPE | Physical | Articles consisting of up to 50% PCR HDPE for contact with fresh milk under refrigeration temperatures (i.e. Condition of Use F), provided the PCR HDPE comes from milk bottles only. |
109 | 5/23/2007 (letter) |
Global P.E.T., Inc. | PET | Physical | Articles (e.g., clamshells) for contact with raw fruits and vegetables and shell eggs, for short periods of time at room temperature or below (i.e. Conditions of Use E through G), provided the PCR PET comes from food and beverage containers (excluding non-food PET containers and industrial PET containers) and the PCR PET complies with 21 CFR 177.1630. |
110 | 6/25/2007 (letter) |
Fraunhofer Institut Verfahrenstechnik und Verpackung on behalf of Uhde Inventa-Fisher GmbH & Co. KG (UIF) | PET | Physical | Articles consisting of up to 50% PCR PET for contact with all types of food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) and the PCR PET complies with 21 CFR 177.1630. |
111 | 8/27/2007 (letter) |
Fraunhofer Institut Verfahrenstechnik und Verpackung on behalf of SIG Corpoplast GmbH & Co. KG (SIG) | Silicon Oxide | Food contact layer applied at a thickness of 100 nanometers for use with PCR PET for contact with aqueous, acidic and low alcoholic beverages (< 8% alcohol content) under Conditions of Use E through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) and the PCR PET complies with 21 CFR 177.1630. | |
112 | 9/12/2007 (letter) |
UltrePET, LLC | PET | Physical | Articles for contact with aqueous and dry foods under Conditions of Use C through G, and fatty foods under Conditions of Use D through G, provided the PCR PET comes from containers previously used for food and beverages obtained from deposit recycling systems, and the PCR PET complies with 21 CFR 177.1630 and other applicable regulations. |
113 | 10/22/2007 (letter) |
Preformia Oy | PET | Physical | Articles for contact with all types of food under Conditions of Use E through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) and the PCR PET complies with 21 CFR 177.1630. |
114 | 10/29/2007 (letter) |
Fraunhofer Institut Verfahrenstechnik und Verpackung on behalf of Starlinger & Co. Gesellschaft m.b.H. (Starlinger) | PET | Physical | Articles for contact with all types of food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) and the PCR PET complies with 21 CFR 177.1630. |
115 | 2/14/2008 (letter) |
Fraunhofer Institut Verfahrenstechnik und Verpackung on behalf of 4PET Recycling B.V. | PET | Physical | Articles for contact with all types of food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) and the PCR PET complies with 21 CFR 177.1630. |
116 | 2/26/2008 (letter) |
Fraunhofer Institut Verfahrenstechnik und Verpackung on behalf of Starlinger & Co. Gesellschaft m.b.H. (Starlinger) | PET | Physical | Articles for contact with all types of food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) and the PCR PET complies with 21 CFR 177.1630. |
117 | 7/30/2008 (letter) |
Keller & Heckman on behalf of Plastic Technologies, Inc.(PTI) | PET | Physical | Articles for contact with all types of food under Conditions of Use B through H, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) and the PCR PET complies with the existing applicable authorizations. |
118 | 11/21/2008 (letter) |
Keller & Heckman on behalf of ECO2 Plastics | PET | Physical | Articles for contact with all types of food under Conditions of Use A through H and J, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) and the PCR PET complies with the existing applicable authorizations. |