Guidelines for using recycled plastics in food packaging: Overview

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• Synopsis
• Introduction

Synopsis

Since 1996, the Bureau of Chemical Safety (BCS) within the Food Directorate (FD) of Health Canada has provided opinions to plastic recyclers and their clients regarding the use of recycled plastic materials in food packaging applications.

The use of recycled materials has become a government of Canada priority, as part of Canada's goal of zero plastic waste by 2030. Moreover, as public demand grows, manufacturers of food packaging will likely increase their use of recycled materials. Therefore, to support this plastic waste reduction policy and to promote the safe use of these materials, BCS has updated its previous guidelines to assist recyclers, manufacturers and sellers of plastic materials in determining the safety and acceptability of post-consumer recycled (PCR) plastics for this purpose.

These updated guidelines detail common recycling practices, with a focus on mechanical recycling processes as these are considered to represent the greatest potential health concern for food contact applications. The guidelines discuss key aspects of the recycling process such as the:

• limitations of use
• source of feedstock (materials to be recycled)
• efficiency of the recycling process in the removal of chemical contaminants

The guidelines are generally consistent with the practices of other international regulatory food safety agencies. As such, petitioners who have received relevant regulatory opinions on their processes from other regulatory agencies are encouraged to submit this information to Health Canada.

This document replaces the previous version that was published on September 20, 2011.

Introduction

These guidelines will assist recyclers, manufacturers and sellers of plastic materials in determining the acceptability and use of post-consumer recycled (PCR) plastics in food packaging applications. The applicable ISO 14021: 2016 standard defines PCR material as a material generated by households or by commercial, industrial and institutional facilities, including returns of a material from the distribution chain.

In Canada, all packaging materials, including those containing recycled plastics, used to package foods sold are subject to the provisions of Division 23 of the Canadian Food and Drug Regulations. Section B.23.001, in particular, prohibits the sale of foods in packaging materials that may impart harmful substances to their contents. Similarly, section 4(1)(a) of the Canadian Food and Drugs Act prohibits the sale of a food containing any poisonous or harmful substance.

Currently, Canadian regulations don't require pre-market clearance of food packaging materials. However, Health Canada's Food Directorate conducts evaluations of the chemical safety of food packaging products, upon request, based on information submitted by petitioners. We conduct these safety assessments on a case-by-case basis taking into consideration the merit of each individual application. If Health Canada considers a product to be acceptable from a food chemical safety perspective, for its proposed or intended use, a 'letter of no objection' (LONO) is issued to the petitioner for the specified food packaging end use. This letter is an opinion from Health Canada on the acceptability of a material based on the information received from the petitioner and doesn't absolve the food seller of its responsibility under Section B.23.001 of the Food and Drug Regulations and other regulations that are relevant to its use.

The use of recycled materials in food packaging applications increases the potential for non-food grade chemicals (including contaminants) to be present in food packaging and that may, in turn, migrate into food. While microbial contamination may also exist, this represents a minimal risk as the processing of recycled plastic materials involves high temperatures and the use of sanitizers and cleaning agents. Therefore, we will not discuss microbial contamination further in this document.

We will also not address the issue of structural integrity of the packaging within these guidelines, as manufacturers of all food packaging materials, regardless of whether they contain recycled materials, are responsible to ensure that the packaging products are suitable for their intended uses.

You can access a guidance document titled Information Requirements for Food Packaging Submissions to:

• learn more about food packaging regulations in Canada
• request an opinion from the BCS on the acceptability of materials for use in food packaging applications