Brasil Pack Trends 2020

BrasilPackTrends2020 220 safety & regulatory issues the decontamination process and to approve processes, protocols have been established by the FDA - Guidance for Industry: Use of Recycled Plastics in Food Packaging: Chemistry Considerations (U.S. DEPARTMENT..., 2006) and by the EFSA - Guidelines on submission of the dossier for safety evaluation by the EFSA of a recycling process to produce recycled plastics intended to be used for manufacture of materials and articles in contact with food (GUIDELINES..., 2008). The protocols require that the material must be contaminated with model contaminants, representative of substances that may be present in the material after use, and then must undergo a cleaning process (Challenge test). By the end, the contaminants should be quantified in the material, and migration testing or estimations of migration should be performed. No migration may be detected, i.e. it must be below the detection limit of the method. The Challenge test is the first step toward approving a process for recycling post-consumer plastics for food contact. To regulate all the requirements for this type of material, specific legislation for recycled materials for food contact were established by the European Union, United States and MERCOSUR / Brazil. The European Union established Regulation (EC) N° 282/2008 (COMMISSION OF THE EUROPEAN COMMUNITIES, 2008). This regulationprovides individual authorization for processes within the Community after the safety assessment of the recycling process conducted by EFSA (SCHAFER, 2010). The source of material to be recycled and the ability of the process to reduce the contamination are considered critical. Only plastics which meet the composition requirements established by the regulations can be used as feedstock for the recycling process. All recycling processes should have a system of quality assurance and should be audited by the member states, and processes as well as packages containing recycled material must be accompanied by a declaration of compliance. The final product must meet the requirements of the regulations on plastics and Regulation 1935/2004 (PARLAMENTO EUROPEU, 2004). The United States does not have specific legislation for post-consumption recycled materials. For the process to be approved, the protocol Use of Recycled Plastics in Food Packaging: Chemistry Consideration (U.S. DEPARTMENT..., 2006) must be considered. The results are submitted to the FDA that issues a No Objection Letter (NOL) that contains the name of the company responsible for the process, the type of material, the date of the letter, the type of process (chemical or mechanical), the permitted use and limitations (food, contact temperature and rawmaterial) (U.S. DEPARTMENT..., 2013). PET, for its extensive use in soft drink bottles and also for its characteristics, is the most studied material and has the most recycling processes approved. In 1999 MERCOSUR adopted Resolution GMC 25/99 - Disposable multilayer PET packages intended for the packaging of non-alcoholic carbonated beverage - which allows use of the middle layer of recycled post- consumer PET (published in Brazil as Ordinance No. 987, of December 8, 1998). This resolution states that the layer which comes into contact with the beverage is virgin PET with a minimum thickness of 25 μm and control analysis should be performed on the bottles to guarantee its quality. The company must be authorized by the competent authority (PADULA, 2010). The use of post-consumer recycled PET for direct food contact was approved in MERCOSUR as Resolution GMC 30/07, in December 2007, and published in Brazil as RDC 20, of March 26, 2008 – Technical Regulation on food grade post-consumer polyethylene terephthalate packages (PET) (food grade PET-PCR), intended to come into contact with food (BRAZIL, 2008). While the laws of the European Union and the United States apply to plastics in general, this MERCOSUR resolution is only for PET. To assess the efficiency of the process, protocols established and authorization given by the FDA and EFSA are accepted and packages must alsomeet the requirements established in MERCOSUR legislation on plastic containers. The responsibility for the quality of PET-PCR is divided among the producer of PET-PCR resin, the producer of PET-PCR packaging and the food producer. It is important in this resolution that the packages and/or precursor articles of food grade PET-PCR must be approved/authorized and registered with the Competent National Health Authority, following established procedures. Controls of the source of raw material, and of the process and quality of the resin obtained are required of the resin manufacturer.