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Verifying Your Plastic Recycling Process for Food Contact

Post-Consumer Plastic Food Contact Testing

The FDA regulates the use of plastics that contact food and under the Code of Federal regulations 21 CFR 177 provides for testing of polymers that are used to package, store, and hold food.   These CFR codes apply only to virgin plastic materials.  Post-consumer plastics provide a unique challenge as the incoming waste stream from curbside pick-ups can involve bottles that have been used to store pesticides, motor oil, or cleaners.  This problem is most severe for plastics recycling for which the majority of tertiary (end user) recycling comes from curbside pickups as opposed to paper recycling for which the majority of recycling involves printer paper from businesses (“office white”) rather than home scrap.

Surrogate Testing for Material Recycling for Food Contact

For all types of material recycling for food contact the FDA recommends surrogate testing.  The material is contaminated with representative surrogates, is run through the recycling process, and is analyzed for the surrogate contaminants.  The end result should be a product that results in a dietary exposure of less than 0.5 ppb of each contaminant in the diet, which corresponds to < 1.5 ug/day estimated daily exposure.  This is the level that produces no observable effect from both acute and long term exposure, including cancer risk.

For plastics it is recommended to soak the plastic material with a cocktail of a mix of volatile polar, volatile non-polar, heavy metal, non-volatile polar, and non-volatile non-polar materials, for example:

10% v/v Chloroform

10% v/v Toluene

1% v/v Benzophenone

1% Tetracosane

1% Copper (II) 2-ethylhexanoate

With the balance being 2-propanol and hexane.

The plastic should be soaked for 2 weeks at 40C, drained, rinsed, and tested for the surrogates.

Obtaining Approval for Post-Consumer Trash to Re-Enter the Food Chain in the US

If the surrogates are cleared by the process, the agency will feel confident that regardless of variation in the incoming stream of post-consumer trash, the recycling process will result in plastic that can safely re-enter the food chain in the US.

Additional Resources

Want to know more about applying for food contact approval in the US? Check out our blog for more information.



Our expert blogger is Dr. Andrew Kolbert, Avomeen’s President/Chief Technical Officer. Andrew has over 20 years of experience executing and managing analytical and product development programs in highly regulated areas, both internally and in external organizations.

Learn more about Andrew’s expertise and experience.