Recycling

Legal Background

The European legislation (Regulation (EU) No 2022/1616) distinguishes between "suitable" and "novel" recycling technologies. Suitable recycling technologies are listed in Table 1 of Annex I, i.e. mechanical PET recycling and recyling in closed product loops.

Legal representative

SAFE+ Certification GmbH may act as legal representative where business operators or other organisations collaborate on the development of a novel technology, representing as a single legal entity these operators or organisations, and act as the developer of the novel technology.

Recycling Process

Input Material

A recycling process must ensure that only plastic that initially complied with the applicable regulations is recycled.

Spiking & Surrogates

For use of the recycled material as a substitute for plastic made from virgin materials, it is be necessary to demonstrate the cleaning efficiency of the recycling process through surrogate contaminant testing.
Selection of surrogates is based on polarity and volatility consideration reflecting the whol band with of potential contaminants by consumer missuse.
Surrogate contaminants represent typical chemicals accessible to the consumer and include volatile polar organic substances, volatile non-polar organic substance, a non-volatile polar organic substances, non-volatile non-polar organic substances, and in some circumstances heavy metal salt.

Contamination of Plastic

An acceptable approach is to fill intact bottles or soak several kilograms of flaked virgin plastic of the type actually used in the recycling process in the selected contaminants at typical concentrations. A mixture of the contaminants could be used so long as the components of the mixture do not react with each other. There is basic understanding about sorption of scientifically sound surrogates in PET which is in the range of 100 to 1000 mg/kg.
To obtain these initial concentrations exposing PET flake rather than intact bottles to the surrogate solutions for at least 14 days at 40°C. The use of intact PET bottles in surrogate testing potentially can result in at least an order of magnitude less sorption of the surrogate contaminants than required, due to the lower surface area of a PET bottle compared to an equal mass of flake. It is recommended that recyclers consider using higher concentrations of volatile surrogates such as chloroform in the cocktail to offset losses that could occur before the flake is analyzed.

Challenge Test

After contamination of the plastic the material is processed with the recycling process. The material input and the output are analzed for the concentration of the surrogates. The ratio between the fraction in the output and the fraction in the input gives the cleaning effciency of the process. In case of several process stepps, e.g. washing, drying, processing, etc. it might be of interesst to analyse the material after each process stepp to find out to which extend individual process stepps contribute to the overall cleaning efficiency.

Safety Evaluation

The SAFE+ Certification GmbH supports you as applicant to compile and apply for a safety evaluation at the European Food Safety Authority (EFSA) or Food and Drug Administration (FDA) - see Petitions section.