To tackle the climate crisis, the European Union seeks to promote the transition to a Circular Economy where products use less material, contain more recycled content and are easily recycled or reused. As part of this drive, the European Commission wants to ensure that “all packaging on the EU market is reusable or recyclable in an economically viable way by 2030”. The use of recycled plastics, especially as Food Contact Materials, is challenging but necessary due to a global convergence on concerns around the environmental impact of plastic. Sustainability objectives and the drive to a circular economy is an increasing demand for all recycled materials, and in particular plastics in packaging. Both, consumer demands and legislative changes have mandated a shift towards manufacturers reducing single-use plastics and the wider implementation of a circular economy.
WHAT ARE PCR MATERIALS?
PCR materials are recovered plastics that are recycled, i.e. re-processed. Mostly they originated from consumers, from used plastic packaging, which the consumer trash in the bin. The stream of such a waste includes: packaging from food products, packaging from cosmetics, household chemicals or medicaments. Therefore, they are a mixture of such materials as: LDPE, HDPE, PP, PS, PET, laminates and other plastics.
WHY PCR MATERIALS?
Currently, the European Union takes the great emphasis great emphasis on increasing the usage of recycled plastics, including PCR plastics, for the production of packaging. The reason for this approach is the desire to reduce the amount of waste being landfilled and reduce the impact of the rainfall on the environment. According to the Single Use Plastic Directive of 2019. By 2025, PET beverage bottles are to contain at least 25% recycled plastic. From 2030, PET beverage bottles are to contain at least 30% recycled plastics. At the same time, the market of packaging for food and cosmetic products strives to produce packaging with the highest possible share of PCR material. This is a trend that has already started from for several years. Packaging made of 100% PCR is already available on the market.
SAFETY PCR MATERIALS AS FCMS
In accordance with the Regulation (EC) 1935/2004 each food contact material must be safe for the final recipient, i.e. the consumer, under foreseeable conditions of use. Regulation (EU) 1934/2004 defines this safety as:
- no chemical release above safe limits,
- no change in food composition,
- no change in the organoleptic characteristics of the food.
Recycled plastics intended to be used in contact with food should also meet the requirements of the Commission Regulation (EC) No. 282/2008. The Work is currently underway to amend this regulation. The current legal status requires the use of PCR plastics behind a functional barrier. The above requirements can also be applied to packaging intended for cosmetics. The packaging manufacturer must ensure constant supervision of the entire production process and the composition in the final product. For this reason, there are additional risks associated with the use of PCR plastics. The most important is the possibility of contamination of the main material with admixtures of other materials. The final product may contain substances that are not allowed to come into direct contact with food, such as printing inks, adhesives, varnishes, coatings. PCR materials may contain substances that are commonly considered harmful and undesirable, such as: bisphenols, phthalates, heavy metals, SVHC substances and others. It should be remembered that production batches may differ significantly from each other.
The safety of food contact materials requires evaluation as chemicals can migrate from the materials into food. The materials should be manufactured in compliance with EU regulations, including good manufacturing practices, so that any potential transfer to foods does not raise safety concerns, change the composition of the food in an unacceptable way or have adverse effects on the quality of foods (for instance, taste and/or odour). For this reason, the scope and frequency of tests should be significantly increased. J.S. Hamilton Poland offers the wide range of analyzes to ensure the safety of the produced PCR materials is achieved.
At J.S. Hamilton, we offer the following services related to food packaging:
- Consultancy on PCR materials as FCMs
- Set-up of optimized testing plans for compliance verification of PCR
- Documents review, DoCs for raw materials verification
- Compliance assessment based on EU 10/2011
- Toxicological risk assessment e.g. by TTC-concept method
- Overall and specific migration for compliance with EU 10/2011
- Non-Intentionally Added Substances (NIAS):
- Headpsace-GC/MS Screening,
- GC/MS Screening,
- LC-QToF-MS Screening,
- ICP-MS Screening,
- Primary Aromatic Amines (PAAs).
- Testing of hazarduos substances:
- Metals
- Bisphenols
- Phthalates
- Alkylphenols
- Perfluorinated alkyl compounds (PFAS.)
- Chlorinated paraffins (LCCP, MCCP, SCCP)
- Mineral oils
- Polycyclic Aromatic Hydrocarbons (PAHs)
- Photoinitiators, acrylates and other compounds of printing inks
- Polybrominated biphenyls (PBB) and polybrominated diphenyl ethers (PBDE)
- Organotin compounds
- Other SVHC substances
Contact our team today to learn more about food packaging tests and the demands of circular economy that your business might wish to satisfy.