Guidelines for Post Consumer Recycled Content in Plastic Packaging

Transcription

G u i d e l i n e s for P o s t C o n s u m e r
R e c y c l e d C o n t e n t in P l a s t i c Pa c k a g i n g
Guidelines for Post Consumer Recycled Content
in Plastic Packaging was developed by the
Sustainable Packaging Coalition , an industry
working group dedicated to developing and
implementing sustainable packaging solutions.
www.sustainablepackaging.org
®
The Sustainable Packaging Coalition is a project of GreenBlue®,
a nonprofit institute that works with the private sector to enable
the positive redesign of industrial systems.
Copyright © 2010 GreenBlue
600 East Water Street, Suite C
Charlottesville, VA 22902
tel 434.817.1824 | fax 434.817.1425
www.greenblue.org | info@greenblue.org
Project Team
Project Lead: Katherine O’Dea
Advisor: Anne Johnson
Design and Illustration: Stephanie Fishwick
G u i d e l i n e s for P o s t C o n s u m e r R e c yc l e d C o n t e n t in P l a s t i c Pac k ag i n g
Contributors
Amanda Atkins
Chris Conley
Amia Scovel
Eastman Chemical Company
Unilever
Sara Lee Corporation
Rafael Auras
Paul Earl-Torniainen
Puneet Shrivastava
Michigan State University School of Packaging
General Mills Inc.
Dell
Phil Barhouse
Patty Enneking
Steve Sikra
Spartech Corporation
Klockner Pentaplast
Procter & Gamble
Jeffrey A. Blum
Cynthia Forsch
Chad Smith
McCormick & Company, Inc.
Eco-Logic Strategies
Earthbound Farms
Linda Bracha
Tony Gallo
Scott Steele
CPT, Inc.
Associated Packaging Technologies
Plastics Technologies Inc.
Lori Carson
Nina Goodrich
Rick Thomas
Phoenix Technologies
Alcan Packaging, Inc.
CardPak, Inc.
Richard Chomik
Bill Hare
Laura Tufariello
Church & Dwight Co., Inc.
Bemis Company, Inc.
Design & Source Productions
Peter Clark
Amanda Holder
Gerri Walsh
Kimberly-Clark Corporation
Berry Plastics
Ball Corporation
Lani Craddock
Joe Keller
Keely Wheaton
Exopack Holding Corp.
Procter & Gamble
Target
George D’Urso
Kevin Kelly
Nicole Whiteman
Smurfit-Stone Packaging Corporation
Emerald Packaging, Inc.
NatureWorks
Eric Clamp
Gwen Lorio
Jeff Wooster
Transparent Container
The Clorox Company
The Dow Chemical Company
David Clark
John Murray
Sheila Young
Amcor
Polyflex
Amcor
1
Introduction
Use of recycled content is of increasing
interest to brand owners and retailers for a
number of reasons, not least because it is an
environmental strategy that is well understood
by consumers. In addition, the use of post
consumer recycled (PCR) content is critical
to the development of markets for recovered
materials as part of a vision to create more
sustainable and effective closed loop systems
for packaging. While general guidance is
available to help packaging engineers and
designers use PCR content in plastic packaging,
there is no comprehensive resource that both
characterizes the opportunity to use post
consumer plastic materials and identifies the
key barriers that need to be overcome to
encourage its intended use in packaging.
These guidelines, developed by GreenBlue
and a working group of Sustainable Packaging
Coalition member companies, are intended to
be such a resource by offering practical and
pragmatic guidance on the use of recycled
content in 27 packaging applications for a
number of different plastics. The information
in this resource is based on the knowledge
and experience of technical practitioners
who design and engineer plastics packaging.
The scope of this guidance is limited to the
experience of the U.S. and the most significant
plastic packaging applications, by volume, within
the seven highest sales categories1 found in
most major retail environments, as shown in the
table to the right.
A standard set of information was collected
for each packaging application and includes
characterization of the opportunity to use
PCR based on:
• Packaging performance requirements
Category
Applications
• Regulatory compliance requirements
• Technical/operational factors
Beverages
• Carbonated Soft Drinks - polyethylene terephthalate (PET) bottles
• Juice - PET bottles
• Bottled water - PET bottles
• Juice - co-polyester bottles
• Misc. drinks - polypropylene (PP) containers
dairy
• Dairy spread - injection molded PP or high density polyethylene (HDPE) tubs
• Yogurt - thermoformed PP tubs
electronics
• Misc. electronics - expanded polystyrene (EPS) foam dunnage
• Misc. electronics - low density polyethylene (LDPE) bags
• Misc electronics - polyvinyl chloride (PVC) clamshells
• Misc. electronics - PET blister Packs
Household Care & Laundry
• Household cleaners - PET clear bottles
• Household cleaners - rigid PET colored bottles
• Laundry detergents, fabric softeners and laundry additives – HDPE bottles
Over-the-counter (OTC)
pharmaceuticals
• Medicines (e.g., lozenges) - co-polyester blister packs
• Toothbrushes - PET blister packs
• Vitamins, pain medications and other - PET bottles
• Vitamins, pain medications and other - white HDPE bottles
• Razors PET clamshells
Personal Care Products
• Shampoos and conditioners - HDPE bottles
• Shampoos, conditioners and soaps - PET bottles
• Anti-perspirants and deodorant sticks - PP containers
• Liquid makeup - PP bottles
• Powder makeup - copolyester jars
• Mascara – HDPE tubes
Snacks
• Chips – reverse-printed oriented polypropylene (OPP) bags
• Chips – metalized and laminated to reverse-printed OPP bags
• Aesthetic considerations
• Material availability
• Cost
This resource should benefit both producers
and users of consumer plastic packaging. By
providing detailed and specific information
related to the use of recycled content,
retailers can be better informed and more
proficient in specifying recycled content. These
guidelines can help inform aggressive packaging
specifications that converters can realistically
strive to deliver. The information also can
help to minimize research and development
costs involved in conducting (or duplicating)
independent research into the appropriate
parameters for recycled content use in specific
packaging formats.
Opportunities for PCR Use
While all plastics are technically recyclable, a
number of factors contribute to the feasibility
of incorporating PCR content into various
packaging applications, some of which are
shown in Figure 1. These factors or conditions
vary by plastic type and packaging application
and have a direct impact on how much, if any,
PCR content can be incorporated into a specific
packging format. As material collection programs
increase, material sorting infrastructure improves
and material processing technologies evolve, the
opportunities to use or increase PCR content will
likewise evolve and increase.
1
he categories were identified by looking at sales performance
T
at Wal-Mart stores.
figure 1:
FDA Requirements
21CFR177 for Food &
Drug Applications
Technical
Considerations
Aesthetic
Considerations
Market Limitations
Color Consistency/
Matching
Demand Exceeds
Supply
Resin Incompatibility
Transparency & Clarity
Price Fluctuations
Polymer Degradation
Odors
Material Exporting
Process or Equipment
Modification
Resin Char
Material Quality
Contamination
2
Introduction
Among the product categories and packaging
applications included in this assessment, the
greatest opportunities to use post consumer
recycled content, ranked from highest to
lowest are in:
•PET in electronic equipment blister packs.
•PET and HDPE in household cleaner
bottles and laundry detergent jugs and
laundry additive containers.
•PET and HDPE in shampoo, conditioner
and soap bottles.
•PET in carbonated beverages, water and
juice bottles.
Not surprisingly, these packaging formats
already contain the highest average
percentages of recycled content in the market
place ranging from:
•35 to 50 percent for electronic equipment
blister packs.
•25 to 35 percent for household cleaning/
laundry and shampoo, conditioner and soap
packaging.
•Approximately 10 percent for the beverage
containers.
The primary reasons that higher percentages
of PCR content are used in these applications
include that:
•PET bottles at 27 percent2 and HDPE
bottles at 29 percent3 have the highest
recycling rate in the U.S. due to a fairly
wide-spread infrastructure for collection
and sorting, which translates into an
economic supply for these plastics.
•Some of these applications are not required
to meet Food and Drug Administration
(FDA), Health Canada or the European Food
Safety Authority (EFSA) requirements,4 and
FDA “no objection letters” have already
been issued to some suppliers for PET use in
beverage containers.
•The packaging formats for some
applications are multi-layer and the PCR
content can be incorporated into a middle
layer where direct food or drug contact is
not a consideration.
•Some states mandate a minimum of 25
percent recycled content use in certain
household cleaners, laundry and personal
care product packaging.
A small number of applications currently use
low levels, (i.e., less than 10 percent) of PCR,
but are believed to have a medium to high
potential to increase the use of PCR in the
short- to mid-term. These include PP yogurt
tubs, PET toothbrush blister packs and PET
razor clamshells. Collection of PP is increasing
with approximately 43 percent of the U.S.
population5 having access to an existing mixed
plastics curbside or drop-off facility recycling
programs. And, since PET is the most recycled
plastic in the U.S., it makes sense that the
potential exists to increase PCR content in
some non-bottle applications. All three of these
applications face a major hurdle beyond material
availability, however, and that is compliance with
FDA, Health Canada and/or EFSA, which can be
both time consuming and costly.
Finally, almost 50 percent of the package
applications reviewed in this process do
not utilize any recycled content, and in the
estimation of the working group, the ability
to introduce PCR content in the short term is
considered to be low. Despite a trend toward
mixed plastics collection, most material
recovery facilities (MRFs) do not have the
capacity to separate number 3 through 7
plastics, so they are baled and sold as mixed
plastics. As a result, these materials are almost
always downcycled into products such as plastic
lumber and flower pots. Additionally, the use
of post consumer recycled content for most
of the following applications – copolyester
and PP beverage containers and cosmetic
bottles and jars, PP and HDPE dairy tubs, OTC
pharmaceutical blister packs, pill bottles and
mascara tubes – would also need to meet the
FDA’s Code of Federal Regulations Title 21 Part 177
(21CFR177) for direct food and drug contact.
Common Challenges
Five factors emerged as the primary challenges
to increased recycled content use:
•Lack of material collection and sorting
infrastructure.
and consumer expectations. Education and
marketing, however, can facilitate shifts in
consumer perception and expectation in order
to change expectations around aesthetics.
The issues around cost are very individual and
need to be considered in terms of a company’s
sustainability objectives, market positioning and
overall financial goals and projections.
2National Association for PET Container Resources, 2008,
Report on Post Consumer Recycling Activity, p. 4.
• Lack of or limited material markets.
3Association of Post Consumer Recyclers and American
Chemical Council, 2008, United States National Post Consumer
Bottle Recycling Report, p. 3.
•International market competition for
existing recovered materials.
4FDA, Health Canada and EFSA compliance is discussed in more
detail in the Direct Food and Drug Contact Compliance session
of these guidelines.
•Direct food and drug contact requirements
compliance.
5R.W. Beck, (for the American Beverage Association), 2009, 2008
ABA Community Survey, Final Report, rev. 2, p.13.
•Critical performance requirements such as
material strength and environmental (e.g.,
Ultraviolet light (UV), moisture) barriers.
Additional considerations are generally related to:
• Material quality.
• Cost variability.
•Required process modifications that may
affect inventory management, material feed
and process cycle time.
•Aesthetics depending upon consumer
sensibilities and market positioning.
Many of the challenges identified in this study
can be overcome, and some known solutions
are offered in these guidelines. Whether a
challenge becomes an actual limitation often
depends upon a supplier’s and/or customer’s
level of comfort with making trade-off decisions.
While the functional integrity of the packaging
should never be sacrificed, aesthetic standards
can be modified in some instances without
risking market share. Such decisions must be
made on an application-by-application basis
and with a good understanding of market
3
Introduction
The most difficult challenges are clearly the
lack of (virtually non-existent) infrastructure
for proper collection and sorting of number
3 through 7 plastics, and complying with the
direct food and drug contact requirements. But
even where collection and sorting infrastructure
does exist and markets have been developed,
demand for recycled content exceeds supply.
For example, packaging substrate manufacturers
and converters compete for recycled PET with
producers of carpeting, textiles, construction
materials and strapping, and it is generally easier
and less expensive to process recycled material
for these bulk applications.
Best Practice Examples
Despite the challenges, several PCR resin
processors and packaging converters have
identified and adopted process technologies
to incorporate increasing amounts of PCR
content into the substrates and packaging
formats they produce for a variety of consumer
product goods companies (CPGs). Examples of
above average PCR use in certain applications
are shown in the table below: Some of these
packages may include additives and colorants
that are considered proprietary and many of the
highest PCR content usages are for products
with limited or niche markets, meaning access
to sufficient quantities of PCR material is less
of a challenge. The best way any company can
explore the introduction or increased use of
recycled content into any plastic packaging
application is to discuss goals and objectives,
performance requirements and technical
capabilities with their supply chain partners.
Design Process
In all package development, the design phase
is a critical point to ensure the performance of
company
product package application
pcr content
Aveda
HDPE cosmetic bottle
100%
Dell
HDPE molded packaging cushion
100%
Earthbound Farm
PET salad clamshells
100%
Innocent Ltd
PET juice bottle
100%
Lush
PET bath and body product bottles
100%
McCormick Distilling Company, Inc.
PET 50 mL 360 brand vodka bottle
100%
Method
PET all surface cleaner bottle
100%
Naked Juice
PET juice bottle
100%
Naya
PET spring water bottle
100%
Proctor & Gamble
HDPE Cascade brand dishwasher rinse agent
100%
Aveda
Copolyester cosmetic bottles and jars
80-100%
Radius
PET toothbrush blister pack
50%
Toshiba
PET Electronics component blister pack
50%
the package meets requirements and there are
not unintended consequences. Therefore, the
use of PCR should not increase the potential
for product damage or scrap as this would
adversely impact the environment and offset
the benefit of the PCR use. Likewise, the use of
PCR should not require increased use of other
materials to ensure product protection. Design
teams should also consider manufacturing
processes and understand if the use of recycled
content requires additional processes or
increases cycle times, either of which could
increase energy use.
Best Practice Tips
Some best practice tips for the successful use of
recycled content in the design and manufacture
of plastic packaging applications include:
•Be clear about the material specifications
for the package and ensure they are
performance-based, not material based.
•Consider adjusting the design of the
package to accommodate recycled
content, but be careful not to design-in
other unintended environmental impacts
in the process.
•Choose a reputable plastics recycler
who can provide detailed technical data
and inspection sheets as well as good
customer support.
•Develop long-term relationships with
suppliers to ensure access to limited supply,
secure more stable and favorable pricing
and have easy access to technical support.
•Design the recycled content package so it
can be recycled again.
•Support recycling infrastructure
development for increased material
collection and improved sorting.
•Support development of innovative
recycling process technologies to facilitate
closed-loop recycling of all plastic types.
4
Performance Requirements
Packaging serves many important functions
in a product system. Packaging’s primary role
is to protect the product and the product’s
embodied resources from damage or loss
during transport, and in the warehouse or
retail environments. Packaging can also
extend product shelf-life, and prevent product
tampering, keeping products safe for use under
a variety of conditions. Packaging is also used to
convey important product information ranging
from dosing instructions on pharmaceuticals, to
nutritional information on food and beverages, and
safe handling instructions on electronics and other
fragile products.
Performance requirements will vary
according to packaging format and application,
as well as required processing, conversion, fill
and distribution processes. Many packages
need to provide critical environmental
barriers such as oxygen, moisture and UV light
protection. Some packages must have anti-static
properties; others will be required to withstand
top filling and/or hot filling. Still others must be
able to be die cut, laminated or heat sealed.
Most of the physical properties of mechanically
recycled PCR materials are lower than the
virgin form of the materials because the
polymer chains can be broken: 1) from repeated
heating and shearing of the plastic in the
extruder; 2) as the result of prolonged exposure
to UV light in a previous application; or 3) due
to stress cracks sustained during its previous
use(s). A plastic’s heat history (i.e., the number
of time it is exposed to heat in the extrusion
barrel during reprocessing) can impact the
resin’s intrinsic viscosity (I.V.) and/or cause the
formation of “gels,” which are fractions of the
polymer that become insoluble, particularly at
high conversion rates.
Additionally, material properties are
impacted by incomplete removal of
contaminants (e.g., residual product,
attachments like labels and closures and
other debris) as well as from mixing similar
materials with different physical properties.
Therefore, introducing recycled content
into packaging applications that have critical
chemical or structural requirements may not be
appropriate in conjunction with lightweighting
or downgauging.
Intrinsic Viscosity for PET
Intrinsic viscosity is a measure of PET’s
molecular weight and provides insight about
the polymer’s molecular structure. It is also a
common descriptor of PET flowability6. I.V. is
typically measured in deciliters per gram (dl/g)
and it is dependent upon the length of the
polymer chains. The longer the polymer chains
are, the higher the intrinsic viscosity is and the
stiffer the material will be7.
Intrinsic viscosity is one of the most
important properties of PET in terms of
performance because of its affect on material
strength, which is a critical parameter for top
load strength, drop impact resistance, ability
to hold pressure and barrier properties.
Carbonated soft drink bottles, for example,
typically require an I.V. of 0.76 - 0.80 dl/g.
This requirement may limit the percentage of
recycled content that can be used in some bottle
applications since one of the most effective ways
to maintain required I.V. is to blend some virgin
material with the recycled content.
Chemical recycling of PET has less affect
on I.V. and gel formation because the process
essentially de-polymerizes the recycled
material allowing its monomers to be used
as raw material in the manufacture of a new
polymer. However, chemical recycling is
relatively uncommon and more expensive than
mechanical recycling. Achieving effectiveness
and efficiency in chemical recycling requires the
ability to process materials in quantities of at
least 50,000 tons per year8. On the other hand,
according to plastic recyclers that participated
in the development of this resource, economic
effectiveness and efficiency can be achieved in
mechanical recycling at processing quantities
ranging from 5,000 to 20,000 tons per year.
Additives
Some techniques that can address the
degradation of physical properties in recovered
plastics include resin compounding, blending
of various grades of a resin and/or introduction
of performance additives. The introduction of
new high-performance polyethylene plastics
can compensate for some property deficiencies
in recycled HDPE. This involves blending the
recycled HDPE resin with an environmental stress
crack resistant (ESCR) HDPE resin. However,
additives may not work under all conditions as
some research has shown that stress cracking
agents can minimize cracking at low stress levels
but may actually accelerate it at high stress levels9.
Performance additives include but are not
limited to:
•Anti-oxidants, UV absorbers, and anti-block
agents that can increase the stability of the
reclaimed/reprocessed resin.
•Colorants may be added for aesthetic or
marketing purposes, but are also used
as stabilizers. Dark colors contribute
to opacity in a product that can reduce
material degradation by sunlight. For
example, carbon black in HDPE reacts very
positively with anti-oxidants to produce a
highly stable material that is highly resistant
to degradation by UV light and sunlight.
• Lubricants can facilitate processing.
•Antistats minimize the potential for a static
charge to develop.
Atmospheric Barriers
Barrier properties such as UV, oxygen, moisture
and/or odor and flavor transfer protection may
need to be carefully monitored and controlled
when introducing or increasing recycled content
into packaging applications. These attributes
can be achieved by multi-layering or permeating
the polymer with a variety of chemical additives,
barrier materials or scavengers10. These
methodologies are generally compatible with
the use of recycled content, but may require
some special storage and handling of the
additive resins, special equipment to optimize
blending and additional testing procedures.
6Clean Washington Center, January 1998, “Best Practices in PET
Recycling.”. < www.cwc.org/pet_bp/3-06-01.pdf>
7
Encyclopedia of Chemistry. www.chemie.de>
8Thiele, U.K., 2009, Collection of Publications, “Polyester
Recycling Industry.” www.polyester-technology.com/index.html
9Chico State University, Chico Research Foundation (for the
California Integrated Waste Management Board), 2005,
Postconsumer Resin Quality Assurance and Testing Protocol,
p 8.
10Brody, A. L., Bugusu, B., Han, J. H., Koelsch-Sand, C., McHugh, T.
H., 2008, Journal of Food Science, “Innovative Food Packaging
Solutions,” Vol. 73, No. 8.
•Fillers can provide a variety of functions
including increased opacity, increased
material density, enhanced stiffness, flame
retardation or a modified melt index.
•Impact modifiers can improve strength or
toughness.
5
Sterilization
Some packaging applications must be capable
of being sterilized. Similar to achieving
atmospheric barrier attributes, sterilization
compatibility can be achieved using additives
or special processing techniques such as
gamma irradiation or the use of a low energy
electron beam. These processes can affect the
polymer chain and thus may impact barrier,
strength and tensile properties of virgin resins,11,
12
so it is particularly important to control
material viscosity and melt flow density when
incorporating PCR resins into packaging that
will undergo sterilization.
If the quality is poor, then the material can be
discarded or blended with some conforming
material13.
11McCarthy, S., Norasetthekul, S., Reddy, R., 2010, “Material
Effects of Low-Energy EB Treatment of Polypropylene and LowDensity Polyethylene.” RadTech Report, April/May.
12Massey, L. K., 2005, The Effects of Sterilization Methods on
Plastics and Elastomers, pp. 1-13.
13Chico State University and Chico Research Foundation (for
the California Integrated Waste Management Board), 2005,
Postconsumer Resin Quality Assurance and Testing Protocol, p 10.
Heat Sealability
Not all plastics with recycle content lend
themselves well to heat sealing because
contamination and a variety of additives in the
PCR resin may impact the ability of the resins to
seal. Additionally, the solvents used for sealing
and/or the temperatures required to make
the seal can affect the mechanical properties
of polymers. Water-based heat sealants are
beginning to enter the market and can currently
support the use of recycled content in blister
pack applications.
Testing
Mechanical tests to evaluate recycled resins
and determine their suitability for the packaging
applications covered by these guidelines are
well established. Methodologies are readily
available for testing tensile strength, percent
elongation, impact strength, heat seal range,
water and oxygen permeability and residual
odors and flavor transference. One of the
most effective methods to check the quality of
PCR is by running a small batch of extrusionblown-film. In a film format the material can
be checked for stability, bubbles, gels, color,
odor, strength and other quality measurements.
6
Food and Drug Direct Contact Compliance
According to Keller and Heckman LLP, a law
firm with a well respected food and drug
practice that also specializes in packaging law,
there is no legal requirement to obtain FDA’s
approval for a plastics recycling process. If a
plastic is approved by FDA for packaging food
as required by 21CFR177, FDA compliance is
not affected by whether the packaging material
is “virgin” or recycled. In practice, however,
most consumer product companies want FDA’s
opinion on the effectiveness of a recycling
process in removing potential contaminants
from the PCR14.
As a result, most converters seeking to
incorporate recycled content into direct food
or drug contact packaging application will
petition for a “no objection letter” (NOL) – also
referred to as a “letter of no objection (LNO)
¬– from the FDA. Depending on the market for
the intended packaging application, similar
“non-objection” from Health Canada and/or
EFSA may be advisable.
While securing an NOL/LNO is not
mandatory, compliance with the Code of
Federal Regulations 21CFR177 concerning
indirect food additives is mandatory for all
virgin and PCR plastic that will come in direct
contact with food, beverages, pharmaceuticals
and certain other products, such as dandruff
shampoos and deodorants. An NOL/LNO
provides an opinion issued by FDA that says
the process will yield packaging that complies
with the Code of Federal Regulations under
the intended conditions of use. Therefore, it is
important to ensure that the use of PCR and
any required additives will meet the 21CFR177
requirements before petitioning for an NOL.
Understanding the
Requirements
To facilitate the NOL process, the FDA
has published a guidance document titled,
Guidance for Industry – Use of Recycled Plastics
in Food Packaging: Chemistry Considerations.
It was published in 1992 and while most of the
information remains valid, there have been some
changes in allowable tolerances. Therefore, it is
advisable to check with the FDA or other expert
resource for subsequent updates.
Beyond the FDA guidance document,
considerable information regarding the process
can also be found on the FDA’s website15. For
example, the website indicates that the agency’s
main safety concerns regarding the use of
recycled plastic materials in food and or drugcontact articles are that:
•Contaminants from the post consumer
material may appear in the final foodcontact product.
•Post consumer material not approved for
food-contact use may be incorporated into
food-contact packaging.
•Additives in the recycled plastic may not
comply with the regulations for foodcontact use.
Further, the FDA website suggests that if a
manufacturer is interested in having the FDA
consider the use of recycled material in a
specific packaging application, the company
should provide the following information:
•A complete description of the recycling
process, including a description of the
source of the recyclable plastic and a
description of any source controls in place
that are intended to ensure only plastic
that initially complied with the applicable
regulations is recycled.
•A description of any steps taken to ensure
that the recyclable plastic has not been
contaminated either before collection for
recycling or during the recycling process.
•The results of any tests performed to show
that the recycling process removes all
possible contaminants16.
•A description of the proposed conditions
of use for the recycled plastic (e.g.,
information on intended temperature of
use, type of food with which the plastic
will come into contact, the duration of
the contact and whether the food-contact
plastic will be for repeated or single-use
applications).
Similar information regarding the use of
recycled content in food and drug applications
for the Canadian market can be obtained
from Health Canada. The Health Canada
website includes a resource titled Guidelines
for Determining the Acceptability and Use
of Recycled Plastics in Food Packaging
Applications17. The EFSA has also issued a guide
on food grade plastic recycling, which can be
downloaded from the EFSA website18.
Getting Help
Specific guidance for submission of a food
contact notification or petition for an NOL/
LNO is also available on the FDA website
in a document titled, Guidance for Industry:
Preparation of Food Contact Notifications:
Administrative, which was issued in June 2000
and revised in May 2002. Searching the FDA
website – or even just browsing the internet – for
keywords “FDA no objection letter,” will yield
examples of NOL/LNOs that have already been
issued. Reading through a sampling of those
letters can provide some additional insight into
the process.
Petitioning for an NOL/LNO can be a
complicated and time consuming process.
Therefore, many companies seek the advice of
specialized legal professionals.
Health Canada or EFSA is to limit recycled
content to middle layers in multi-layer package
construction where a virgin outer layer serves
as an effective “functional barrier.” However,
since the effectiveness of the functional barrier
depends on the chemical nature and thickness
of the outer layer as well as the conditions of
use for the packaging, it may still be necessary
to demonstrate – by testing and with scientific
data – that the barrier will protect foods or
drugs from migration of contaminants.
While limiting PCR to middle layers may make
sense in various applications, it is impractical to
go to a multi-layer construction simply to utilize
recycled content. The impacts associated with
the additional virgin material use, the energy
required for the additional processing and the
associated greenhouse gas and other emissions
would likely far outweigh any benefit.
14 www.packaginglaw.com
15www.fda.gov/Food/FoodIngredientsPackaging/
FoodContactSubstancesFCS/ucm093435.htm
16Surrogate contaminant testing and, if appropriate, additional
migration testing is required to demonstrate that the recycling
process successfully removes possible contaminants except in
the case of PET or polyethylene naphthalate (PEN) PCR. The
FDA has determined that tertiary recycling processes produce
PCR-PET or PEN of suitable purity for food-contact use and no
longer sees a need to evaluate tertiary recycling processes for
PET or PEN or to issue individual opinion letters for them.
17www.hc-sc.gc.ca/fn-an/legislation/guide-ld/recycled_guidelinesdirectives_recycle01-eng.php
18www.efsa.europa.eu/en/scdocs/doc/1208.pdf
An Alternative
One way to introduce or increase PCR content
in direct food contact packaging without
having to consider compliance with 21CFR177
or petitioning for an opinion from the FDA,
7
Technical/Processing Considerations
The polymer industry is highly technical, and
manufacturers normally require polymers of a
specific molecular weight and structure that
are blended with additives and formulations
to match their own conversion processes and
end use requirements. Therefore, there are a
number of technical parameters to consider
when introducing or increasing the use of PCR
content in most of the packaging applications
examined in this resource. Considerations range
from resin incompatibility to contaminants
in the recycle stream, flake and pellet
blending to material melt flow rates, and
material inventory management to process or
equipment modifications.
Resin Incompatibility
Almost all plastic products are imprinted with
a resin material identification code – a small
number enclosed by chasing arrows – adopted
by the Society of Plastics Industry (SPI) in 1988
to indicate the general “family” of chemical
compounds used in a product or package. The
iconography of the SPI codes is unfortunate
because of its similarity to the mobius
loop recycling symbol. The SPI codes are
intended to indicate material identification,
not recyclability, but they are frequently
misunderstood by consumers.
Although there are only seven resin SPI
codes, there are hundreds of different types
of plastics. Different combinations of dyes and
other additives blended with the basic resin to
produce a desired color, shape and/or texture
in a final product can alter melting points and
other physical properties of plastics bearing
the same resin code. These additives may also
affect the health profile of the plastic, and are
one of the primary reasons that plastics, in
general, are much more difficult to recycle than
steel glass, aluminum or paper.
Today, in both the U.S. and Canada, most
plastic still ends up in the landfill, from which a
percentage may be transferred for incineration
with or without energy recovery. Despite
increasing promotion of plastic recycling across
North America, most MRFs only have the
capacity to sort number 1 PET and number 2
HDPE plastics and typically only recover PET
and HDPE bottles and jugs. As a result, MRFs
that accept mixed plastics – plastic numbers 1
through 7 (or some combination thereof) – bundle
and market non-bottle PET and HDPE with the
numbers 3 through 7 plastics as mixed bales. For
the most part, these mixed-bale recycled plastics
are only appropriate for downcycling into plastic
lumber and similar bulk products. Additionally,
the technology employed by a majority of MRFs is
not 100 percent accurate in separating out even
number 1 and number 2 plastic bottles, so it is
not that uncommon for some other plastic resins
(PVC in particular) to end up in, for example, a
PET recycling stream.
Such contamination is one of the most
significant challenges in using PCR plastics.
Most plastic types are not compatible with
each other due to inherent immiscibility at the
molecular level, and differences in processing
requirements. For example, a small amount
of PVC contaminant in a PET recycle stream
will degrade the recycled PET resin because
hydrochloric acid gas will be released when
PVC is subjected to the temperatures required
to melt and reprocess the PET. Conversely, PET
in a PVC recycle stream will form solid lumps of
undispersed crystalline resin which significantly
reduces the value of the recycled material19.
PET and HDPE separation is fairly easy to
manage. Even if all of it is not separated during
the mechanical and hand sorting processes, PET
and HDPE flakes can be effectively separated
in latter stages of the material washing or
cleaning process. Following the primary wash
cycle, the plastic chips/flakes are rinsed and
then subjected to a water “cyclone” which
will separate most non-compatible plastic
types that were not caught in earlier sorting
processes based on their density. For example,
PET is heavier than most other plastics so it
will fall to the bottom while other plastics,
including HDPE, float to the top. But this float/
sink process will not detect PVC, which is very
similar in density to PET.
Notable Sorting
Innovations
Identification by Tracers
In 2009, the French Environment and Energy
Management Agency and the French Industry
University Cooperative Research Network
funded a study that focused on the detection
of rare earth oxides used as tracers for the
identification of polymer materials. The
process involves the use of X-ray fluorescence
spectrometry, which takes static measurements
of the spectrum of plastics in a mixed bale
or sample, based on the concentration level
of the earth oxides added to the polymer
mix. Tests were conducted on PP, and they
demonstrated that it was possible to detect
five of the seven tracers added to PP samples
when tested for a one-minute exposure time
and at a concentration level of 1000 ppm.
However, the tests also indicated that two
parameters – required concentration levels of
the oxide additive and acquisition time, i.e., the
time interval required to attain synchronism –
would limit market viability of the technology.
Improvements to reduce the concentration
level and acquisition time of the tracers are in
process with the objective of developing a pilot
plant devoted to the optimization of these two
parameters and further proof of concept20.
Sandia National Laboratories, which works
with the U.S. Department of Energy, has
designed a device to classify plastic waste
into one of the seven plastics categories.
Near-infrared light is used to distinguish one
plastic from another using the vibrational light
characteristics unique to each. Sandia engineers
report that the device can classify many types
of plastics with a success rate of 98 to 100
percent. The laboratory has issued a license for
commercial development of this new device21.
Infrared sorting technology is used in some
MRFs in the U.S., but in general, infrared and
other sophisticated technologies are quite
expensive and not widely used, especially
in municipally owned operations. Until that
dynamic changes, identifying and developing
long-term relationships with a quality recycler
is currently the best way to minimize mixed
polymer contamination issues. It is also important
to develop and follow some source control
measures, which could include documenting and
maintaining records of all sources of recycled
materials, from related batch numbers through to
production lots of finished products.
Material Contaminants
In addition to the potential for the unintended
co-mingling of certain types of plastic, other
contaminants can find their way into a polymer
recycling stream. These include glass, metals,
dirt and other particulates and product residue,
including toxicants. The trend toward single stream
recycling programs can increase the potential for
contamination. However, product residue, labels,
adhesives, dirt and other particulates can generally
be dealt with via the standard cleaning or washing
process that takes place after the reclaimed plastic
is chipped or flaked.
19Dvorak, R., Hopewell, J., Kosior, E., 2009, “Plastics Recycling
Challenges and Opportunities,” Philosophical Transactions of
the Royal Society, vol. 364, no. 1526, pp.2115-2126.
20Waste Management, 2009. “Addition of Tracers into the
Polypropylene in View of Automatic Sorting of Plastic Wastes
Using X-ray Fluorescence Spectrometry.”
21Lofti, A., 2009, The Earth Work’s Group Recycler’s Handbook
8
Washing
Most plastic chips or flakes are washed at
a temperature of 90 degrees centigrade.
However, recovered HDPE must be washed
at no higher than 40 degrees centigrade due
to its low melting point and potential for
discoloration. Because plastics have a positive
surface charge, an alkaline detergent with a
cationic surfactant is often used to remove dirt,
grease and protein contaminants. Agitation
created by the washing equipment grinds
away adhesives and reduces any paper labels
to fibers. The plastic flake is separated from
contaminants and the adhesive and fiber residue
during the spinning process which forces the
fine particulates out through a screen.
Metals and Glass
Metals (including metalized inks) and glass
contaminants that are not removed during
mechanical or hand sorting, the washing and
spinning processes, or through melt filtration
can cause leaks or blowouts in beverage and
other liquids (household cleaners, soaps,
shampoos, etc.) containers. Blowouts are a
serious concern as they could result in product
loss. To date, there is no cost-effective process
in place to detect finely granulated bits of metal
or glass in later stages of the recycling process.
Therefore, establishing long term relationships
with quality recycled material providers is the
best way to minimize issues related to these
and other contaminants.
Recycled Flake & Virgin
Pellet Blending
Post consumer recycled HDPE and PET
material is generally available in pelletized form.
However, users may find economic advantage
in using recycled flake instead of pellets. Some
issues related to the blending of recycled flake
with virgin pellets, particularly in extrusion
molding processes, have been identified. The
issues relate primarily to the ability to process
the different, co-mingled resin formats due to
bulk density differences without equipment
modification. This is further complicated in the
extrusion blow molding process by the need to
incorporate post industrial regrind from trim,
which can be as much as 50 percent of the
container weight. At least one study22 indicates
that a blend of 25 percent flake provided a
product of acceptable physical and visual
quality, and the mix of flakes and pellets could
be processed on the existing equipment without
any modifications in equipment or process
parameters. Some additional equipment would
be required to mix the flakes and pellets at a
higher ratio. It should be noted that the study
cited examined the blending of flakes and pellet
in a hollow profile extrusion for 1” x 6” and 1”
x 8” fence pickets and may not hold true in a
package to package scenario.
The Clean Washington Center (CWC), a
nonprofit supported by the Pacific Northwest
Economic Region, which focuses on increasing
markets and uses for recyclable commodities,
has developed some best practices related
specifically to HDPE flake and pellet blending.
These include:
•Pre-blending the HDPE post consumer
resin formulations when multiple HDPE
sources and proportions (> 10 percent) are
being converted into pellet or end product.
•Blending on a weight basis to minimize
inaccuracies caused by bulk density
differences between flake and pellets.
•Using gravimetric or other weight based
feeders for supplying blenders when
variations occur in the recycled HDPE
particle size.
•Drying the HDPE mixture after blending for
proper feeding into and processing in the
extruder or injection molding machine.
The CWC also recommends a compounding
step to intimately melt blend several sources
of recycled resin, colorants or additives into
a finished pellet product. Compounding
can use reclaimed HDPE in both clean flake
and pelletized form. If possible, it is best
to compound from clean flake to avoid the
added heat history of pelletized material.
If starting with reclaimed pellet, the added
heat history needs to be taken into account
when establishing processing parameters.
Compounding can prevent variations in the
processability of the melted resin and reduce
the occurrences of inferior end products and
high scrap rates23.
Processing Variabilities
There are a number of resin processing
considerations that should be kept in mind when
working with recycled polymers. Those addressed
here are among the most common.
Melt Flow Rate
The melt flow rate (MFR) is a critical parameter
of thermoplastics, particularly polyolefins, that
varies from polymer to polymer and can differ
between virgin and recycled batches of the
same polymer type. Even well sorted recycled
polymers can show a wide variation of flow
behavior, which can prevent smooth processing
of the recycled material. Testing of the MFR
is the most common quality control flow
measurement in the polymer industry. Various
international standards such as ASTM D 1238,
DIN 53 735, BS 2782, NF 51-016 and ISO 1133
describe methodologies for MFR testing24.
According to ASTM D 1238, melt flow
rate testing measures the rate of extrusion
of thermoplastics through an orifice at
a prescribed temperature and load. The
test involves measuring the flow rate of
polymer melts at very low velocities. These
measurements are expressed in units of mass
melt flow per unit time (g/10 min) and are
commonly used in the commercial marketplace
to distinguish between grades of material in a
product line. They also serve as specifications
to which particular grades of material are
manufactured. Processors use these numbers,
for better or worse, as gauges of how easily a
material will process or whether it will process
at all in a given part geometry25. Blending a
percentage of a recycled thermoplastics with
a percentage of virgin thermoplastic will alter
the MFR of the combined material and could
require modification to the material feed rate
and/or equipment run/processing time.
22Recycling Technology Assistance Partnership, Technology Brief
#PL-99-1, Using Recycled Plastic Flake in an Extrusion Molding
Process.
23Clean Washington Center, Best Practice Guide to HDPE
Recycling. www.cwc.org The CWC has also published a Best
Practice Guide for PET Recycling which is also available at www.
cwc.org.
24 W
unsch, A. and Mozer, K., Test Methods for Characterization
and Optimization of Recycling Polymers.
25Sepe, M., 2007, Unusual Polymer Melt Flow Rates, Part 1, iDES,
The Plastics Web. www.ides.com
9
Additives
Residual impurities (e.g., pigments, fillers,
flame-retardants and others) may be present
even in carefully sorted and cleaned recyclates.
The influence of different residual additives on
mechanical recycling is summarized in the table
to the below26.
Material Restabilization
The best stabilizers for polyolefins, polystyrenes
and most other polymers (excepting PVC) can
include a combination of sterically hindered
phenols with either a phosphite or phosphonite.
In addition to these stabilizers, acid acceptors
(e.g., Ca-stearates) can contribute to improved
material stability. However, the stabilizers are
partially consumed during melt processing and
by exposure to light and heat, which means the
total concentration of stabilizer in any recyclate
is likely to be low27. Replacing the stabilizer and
any damaged phenol will improve the ability to
process PCR and increase its potential to be
used in high value applications.
Sourcing & Quality Control
Sourcing of PCR materials is a very important
consideration. Large PCR material processors
are likely to be compliant with ISO 900128
standards and to have documented quality
procedures for inventory management, material
handling, manufacturing operations and batch
or lot inspection, including tests for customer
specified performance requirements. However,
Additive
Influence
Antioxidants, Hydroperoxide
Decomposers, Processing
Stabilizers
Addition of antioxidants depends on the foreseen application (e.g., on processing
conditions, required service time under given exposure conditions). If possible, the level of
residual stabilizers should be determined prior to addition of the new ones.
Light Stabilizers
Depending on the foreseen applications and service lifetime, an addition of light stabilizers
may be required. Antagonistic effects are possible when mineral acids are present in the
recyclate.
Flame Retardants
Owing to the wide range of flameretardants in the marketplace, mechanical recycling may
not always be possible, since required standards must be met.
Fillers and
Reinforcements
post consumer resins are often produced by
small to medium-sized companies that may
not have the capital to invest in and institute
high-level quality control procedures. The lack
of quality standards can affect the quality of
the PCR resin and limit its ability to be used in
many packaging applications. Therefore, it can
be helpful to establish partnerships with quality
vendors, issue detailed specifications and
require that certain material handling, testing
and inspection procedures be in place.
26Herbst, H., Hoffmann, K., Pfaendner, R., Zweifel, H., 2000,
Conference Paper, Upgrading Recyclates – The Solution for
High Value Applications: Restabilization and Repair, pp. 3 – 4.
27Zweifel, H., 1997, Stabilization of Organic Polymers, SpringerVerlag.
28International Organization for Standardization quality
management standards. www.iso.ch/iso/en/iso9000-14000/
iso9000/iso9000index.html
The mechanical properties of end-materials might be affected. For example, fillers can
cause HDPE and PP to sink during the washing and spinning process, which could result
in the loss of usable material. In PET mechanical recycling processes fillers can cause
filled polyolefins to become a contaminant. Extra wear on processing equipment may also
result.
Plasticizers
Addition of plasticized PVC to unplasticized PVC will result in loss of rigidity. Blending
of finely ground unplasticized PVC is a possible solution, provided that the plasticizer
content is > 10 percent to avoid embrittlement.
Lubricants
Lubricants are suspected to contribute to the degradation of polymers. They can also
build up on molding equipment. Some lubricants have an odor that has been found to
transfer to packaging and may require the use of other additives to avoid the transfer.
Pigments
Mixing different classes of pigments may cause discoloration.
10
Aesthetics
While aesthetics have little or no affect on a
package’s technical performance requirements
or processability, color and appearance can
require special considerations for the use of
recycled plastic in many packaging applications.
For example, bottling water in cloudy, grayish
containers or in bottles exhibiting charring
or other black specks would be perceived as
unsavory and unacceptable to a majority of
consumers. Similarly, many consumers would
hesitate to purchase an over the counter
pain medication in a yellowing or otherwise
discolored bottle.
Color & Clarity
Unlike virgin plastics, which initially do not
contain pigments, recycled plastics are derived
from mixtures of materials that may contain a
wide range of pigmentation. For the most part,
natural, white or lightly colored plastics can
be colored any color for their secondary use.
However, the color may not be as rich or vibrant
as that obtained with virgin material. The
reheating process typically causes clear resins
to take on a somewhat cloudy appearance, and
white or lightly colored resins to take on an
off-white color. Either condition can mute or
dull the desired color. Multiple heat histories
can exacerbate the issue, causing darker
color variations and increasing the potential for
charring. However, introducing antioxidants to the
process can slow the degradation and decrease
the potential for cloudiness or discoloration.
Recycled streams comprised of single color
plastics can generally produce resins of the
same color and vibrancy. Practically speaking,
mixed-color streams can only be recycled into
dark, opaque colors. Going with an opaque
color allows for higher concentrations or
percentages of recycled content, but are not
well suited for some packaging applications,
such as bottled water. On the other hand, a
number of applications that currently utilize
clear or transparent plastics, including some
household cleaning products and personal care
products such as liquid soaps, shampoos and
conditioners, could transition to opaque colorations
to allow for increased recycled content.
When color is a fundamental element of a
corporate brand, recycled content may only
be suitable for use in a middle layer, assuming
the packaging application requires a multi-layer
construction. Although, some large PCR PET
producers have successfully developed custom
pigments to accommodate specific brand
requirements. A good example is Neal’s Yard
Remedies, whose supplier was able to achieve
the brand’s signature colbalt blue color while
making the transition from glass to 100 percent
recycled PET bottles. Another example is
Procter and Gamble’s Downy brand blue bottle.
Their supplier achieves the Downy brand color
by presorting white, blue and red recycled
HDPE flakes and melt compounding them into
Downy blue.
When a packaging application requires
a clear and transparent appearance, use of
recycled content may need to be limited to 25
or 30 percent of the total content. Additives,
such as specially formulated brighteners or
clarifiers, can counteract the gray or yellowishbrown hue typical of recycled resin. These
additives tend to be patented, so it is important
to work closely with suppliers to ensure the
additive is appropriate for use in a specific
application, particularly direct food or drug
contact applications. A good example of a
perfectly clear and transparent 100 percent
recycled beverage bottle is the Naya water
bottle, which meets U.S. and Canadian safety
requirement for direct food contact. It should be
noted, however, that it took the company seven
years of research to achieve this innovation.
Odors
Odors in recyclate come from many sources,
including the polymer itself, degradation of the
polymer additives and/or product (contents)
odor migration. The plastics industry currently
uses various methods and additive technologies
to solve the odor problem. In some applications,
pleasant fragrances such as citrus or vanilla are
added to mask odor. Some additives, including
microporous materials like activated carbon
and aluminosilicates, adsorb or trap odor
compounds and volatile organic compounds.
Others, such as neutralizing additives, bond
with the odor compound to reduce their
volatility. An alternative solution is to remove
odor using stripping agents (like water, nitrogen
or carbon dioxide), which remove volatiles by
degassing in the extruder29.
Gels
Plastics are prone to degradation and the
mechanical recycling process can accelerate
the degradation leading to the formation of
gels in recycled resins. According to Ampacet
Corporation, a leading manufacturer of color
and additive masterbatches, antioxidant
additives can help to control gels by increasing
the thermo-oxidative stability of the recycled
material. Using antioxidants can also facilitate
lightweighting or downgauging even with the
use of recycled content. Moreover, some
antioxidants have already been approved for
direct food contact applications.
and distributed throughout the recycled
thermoplastic. Elastomers can also improve
weatherability and thermal stability30.
Chemical Recycling
Aesthetics can be better controlled
through chemical recycling because of the
depolymerization and reuse of the monomers
to create new polymers. However, as noted
in the Performance Requirements section of
these guidelines, chemical recycling is still
relatively uncommon and more expensive than
mechanical recycling. While there are specific
chemical recycling processes for PET and Nylon
6 that recover specific monomers, for other
polymers chemical recycling is through pyrolysis
or gasification processes in which specific
monomers are not necessarily recovered.
29Markarian, J., 2010, “Controlling Odor in Recycled Polymers,”
SpecialChem. www.specialchem4polymers.com
30Biron, M., 2006, “Plastic Recycling III – Recyclate
Upgrading Thanks to Additives,” SpecialChem. www.
specialchem4polymers.com
Brittleness
Brittleness can change the feel and flexibility
of plastic containers and cause a crackling
sound during use, which is considered a less
satisfying consumer experience and may
contribute to premature breakage. To reduce
the brittleness potential while increasing
levels of PCR content, tiny particles of an
elastomer or rubbery polymer can be dispersed
11
Market Availability and Cost
Inadequate Infrastructure
and Technology
Due to the lack of infrastructure for plastics
collection and sorting, there is simply not
enough recycled plastic available on the market
to meet current demand. This is true even of
the two most commonly recycled plastics—
number 1 PET bottles and number 2 HDPE
jugs. For example, according to the National
Association for PET Container Resources,
only 27 percent or approximately 1,451.5900
million metric pounds (mmlbs) of PET bottles
manufactured are recycled and of that only
141 mmlbs is recycled into food or drug grade
packaging. The majority of recycled PET is
converted into polyester fiber, strapping or
non-food packaging.
A 2008 study released by the Association
of Post Consumer Plastics Recyclers and the
American Chemical Society titled, “United
States National Post Consumer Bottle
Recycling Report,” provides slightly better
recycling statistics for HDPE at 29 percent
or approximately 864.1mmlbs. The study also
indicates that 43 percent of recycled HDPE
goes into non-food bottle containers and
57 percent is converted to piping, lumber,
automotive parts, lawn and garden products,
film, pallets, crates and buckets. Virtually none
is currently recycled back into the source of
most of the HDPE recyclate (milk bottles or
jugs). However, efforts are underway in the U.K.
to begin putting recycled HDPE back into milk
containers, and the program expects to reach
statistically relevant percentages by 2015.
One U.S. recycled plastic packaging
converter has recently received an FDA
NOL/LNO for the use of recycled HDPE in
food grade packaging. Upon completion of
organoleptic testing – testing that the material
meets direct food contact requirements related
to taste, color, odor and feel – they may begin
incorporating the recycled material into direct
food contact packaging for some consumer
brand companies before the end of 2010.
While there is a definite trend towards mixed
plastics recycling across the U.S. and Canada –
today communities in 40 of the 50 U.S. states
representing 43 percent of the population offer
curbside and/or drop-off programs for mixed
plastic recycling – a majority of MRFs cannot
effectively deal with the mixed plastics other
than to separate out the PET and HDPE. The
remaining number 3 through 7 plastics get mixedbaled for market or even diverted to landfill. The
mixed bales have limited value because the mixed
plastics are best suited only for recycling into nonpackaging applications like garden compost bins,
water buckets, fence posts and garden furniture.
Additionally, while there are some domestic markets
for the mixed bales, China is the primary buyer.
China has the labor capacity to further hand sort
and separate the mixed bales into individual plastic
types. But, even there, most of the recovered plastic
is recycled into lumber and some sources indicate a
significant percentage of it is incinerated for energy.
Market Competition
While some recycled plastic, primarily PET
and HDPE, is imported into the U.S., more is
exported. Exporting the recovered material
contributes to both the insufficient domestic
supply and volatile price fluctuations.
In 2008, 214 million pounds of U.S.-collected
HDPE bottle material were exported, which
represents 23 percent of the total bottle
material collected domestically. This was the
same export rate for HDPE as in 2007. For
the same time period, PET exports totaled
54 percent of the total bottles collected
with most going to China. For polypropylene,
approximately 57 percent of what was collected
was exported, primarily as part of a mixed resin
and commingled bales31.
Exports to China increased for several reasons:
•A change in Chinese regulations on scrap
imports.
•Pressure on Chinese companies from global
consumer goods companies, brand owners
and retailers to adopt more environmental/
sustainability practices.
•The rise in oil prices, making U.S. natural
gas-based recycled resins less expensive
than China’s oil-based virgin resins.
•It is less expensive for U.S. recyclers/scrap
dealers to ship material to China than
across the U.S.
Further, the Association of Postconsumer
Plastic Recyclers predicts this scenario is not
likely to change for at least several years. One
strategy to deal with availability challenges is
to source from multiple suppliers, however, it is
important to identify quality, reliable suppliers
and strive to develop long-term relationships
with them. Benefits of developing dependable
supply sources include better access to supply
of recycled resins, the ability to secure more
stable pricing and having good access to
technical support.
Obviously the best way to improve supply risk
associated with cost volatility is to support the
development of better infrastructure to collect
and sort plastics. Some companies are taking
this issue into their own hands. Aveda, an Estée
Lauder Companies brand, is committed to the
use of recycled plastics. To address issues around
availability and quality, Aveda has implemented
take back programs in their stores and in
collaboration with schools.
Various organizations are also launching
programs to help increase recycling rates. For
example, the American Chemistry Council has
partnered with Keep America Beautiful and
the state of California to boost recycling in
California’s rest areas, beaches and parks. The
effort involves the placement of recycled bins
and educational signage. Greenopolis32 is an
initiative of Waste Management, Inc. designed
to actively engage consumers in container
recycling. As consumers recycle packaging
in the recycle bins set up in collaborating
retailers’ stores, they earn reward points that
can be redeemed for discounts on a variety of
purchases from movie tickets to pizza and more.
Price Fluctuation
Fluctuation in both virgin and recycled resin
prices makes it difficult for processors to
control operating risks and meet budget
projections. Moreover, when the price of
virgin resin is low, it is very difficult for endusers to justify purchasing recycled resin,
particularly since quality is generally of equal
consideration as price. Improvements in sorting
and processing technologies will continue to
improve the quality of recycled resins, which
will enable broader market acceptance and
help processors and end users weather pricing
fluctuations. Still, processors should work
closely with customers to identify customized
solutions that make recycled resins more
competitive with virgin.
Some tips for dealing with market volatility are:
•Get informed and understand the market
indicators that affect pricing such as
demand, inventory levels, volume of sales
and virgin resin pricing, etc.
•Collaborate with suppliers to identify
mutually agreeable minimum and maximum
values and volumes.
•Do not get locked into a fixed multi-year
purchasing agreement: negotiate 30-, 60- or 90day plans or agree to a volume-based contract
that allows for monthly price negotiation.
31Association of Postconsumer Plastics Recyclers and American
Chemical Council, 2008, United States National Post Consumer
Bottle Recycling Report, p. 8.
32 www.greenopolis.com
12
Beverages
Applications
EXPLANATIONS / work arounds
Product
Carbonated Soft Drink
Juice
Water
Juice
Miscellaneous
Material and format
PET Bottle
PET Bottle
PET Bottle
Co-polyester
Bottle
PP Bottle
Current average PCR use
<10%
<10%
<10%
Opportunity for increased PCR use
Medium-High
Medium-High
Medium
Low
Low
CO2 barrier
l
l
l
l
UV light barrier
l
l
l
l
Internal viscosity (I.V.) of 0.72-0.80 dl/g
l
l
l
Top load strength/compression resistance
l
l
l
l
l
Drop impact strength
l
l
l
l
l
Oxygen barrier
Hot-fillable
Carefully control I.V.
l
Pallet load balancing capacity
l
l
l
l
Pallet load bulging resistance
l
l
l
l
Fast heatable resin for high cavitation
l
l
l
FDA 21CFR177 (as per virgin material) applies
l
l
l
l
l
No Objection Letter (NOL)
l
l
l
l
l
Contaminated PCR flake
l
l
l
Metal or glass contaminant can cause blowouts and leaks. Partner with a reliable supplier. Facilitate better
marking or labeling of materials for recycling. Design packaging for recycling, minimizing use of possible
contaminants.
Quality of PCR stream variability
l
l
l
Bale quality is deteriorating as more alternative raw material choices come to market. Single stream recycling
contributes to poor quality.Partner with a reliable supplier.
FDA Requirements
Technically an NOL is not required to use PCR in packaging in the U.S., but the material must meet FDA
requirements as per virgin material. See document text for guidance on petitioning for an NOL. PCR
could be used in middle layer (no direct food contact) if container uses a multi-layer configuration.
Technical Considerations
PCR intrinsic viscosity variability
l
l
l
Mechanical recycling can result in I.V. of less than 0.72 - 0.80 dl/g., therefore, light weighting and recycled
content use may not be compatible.Blending virgin with the PCR resin can achieve required IV. Chemical
recycling is less likely to affect I.V. as polymer is essentially depolymerized and remade as virgin. However,
achieving effectiveness and efficiency in chemical recycling requires ability to process materials in
quantities of > 50,000 tons/year.
Gels in PCR
l
l
l
Quality suppliers can remove materials with gels by proper sorting.
PCR crystallization rates variability
l
l
l
Can be controlled by specifying I.V. requirements.
Fast heat processing limitations
l
Fast heat resins are required for high cavitation. Resin additives can increase processability.
Potential flavor migration
l
l
l
Flavors from lemon or lime contents can migrate into plastic containers and may be retained in the PCR
flake. Higher levels of acetaldehyde used to reprocess PET can
also affect taste of beverage put into bottles with PCR content. Can be corrected using a variety of
decontamination equipment/processes.
Cost of material
l
l
l
Few mechanical recycling technologies can provide a cost advantage over use of virgin resin and the
processes to recycle PET into fiber, strapping, and thermoform are usually less costly than reprocessing
into bottle-grade resin. Mechanical recycling cost efficiency can be achieved at a processing capacity
within a range of 5,000 - 20,000 tons/year.
Separate handling infrastructure required
l
l
l
Includes inventory tracking and SKU management as well as material processing rates on certain
equipment. Set up appropriate, automated systems, avoid siloing and streamline operations. Securing a
constant and reliable source or supplier of PCR can minimize complexity.
Technical considerations currently N/A
l
l
Very limited amount of recycled copolyester and PP available in U.S. today.
13
Beverages
Applications
Product
Carbonated Soft Drink
Juice
Water
Juice
Miscellaneous
Material and format
PET Bottle
PET Bottle
PET Bottle
Co-polyester
Bottle
PP Bottle
Aesthetic Considerations
Color consistency
l
l
l
Colors can be darker and/or more yellow due to either contamination in the PCR
stream or the resin’s heat history. Color can tend toward increased brownness if resin is allowed to sit in
the dryer. Remove the reprocessed material as quickly as possible. Adding brighteners may be an option.
If color is associated with a brand, recycled content may simply not be a viable solution. As reprocessing
technology evolves, coloration issues may diminish.
Clarity/transparency
l
l
l
If clarity or transparency is important PCR may not be viable. If bottle can be colored green or amber, etc.
use of PCR may be more viable because the PCR color and inconsistency are more easily masked..
Resin charring/dark specs
l
l
l
Brittleness
l
l
l
Brittleness is a function of I.V.
l
Aesthetic considerations currently N/A
l
PCR Availability/Market Limitations
PCR material generally more expensive than virgin
l
l
Pricing fluctuates, so PCR is not always more expensive. Developing long term, negotiable-rate contracts
with suppliers can help to control cost.
l
l
Economics prohibitive
Demand for PCR material exceeds supply
l
l
l
Majority of recycled PET is converted into polyester fiber, strapping or non-food packaging. Further,
according to NAPCOR (2008), only 27% of PET bottles are recycled or approximately 1,451.5 mmlbs. Of the
1,451.5 mmlbs only 141 mmlbs is recycled to food grade.
Food grade PCR availability is low and regional
l
l
l
Most food grade PCR is processed in Eastern U.S. which can add transport costs and GHG emissions.
Support growth of recycling industry in other regions.
l
l
l
l
Completely inadequate collection/sorting infrastructure
International competition for PCR material
14
Dairy
Applications
Product
Dairy Spreads
Yogurt
Material and format
Injection Molded PP or HDPE Tubs
Thermoformed PP Tubs
0%
0%
Low
Medium
Oxygen barrier
l
l
UV light barrier
l
l
Anti-static properties
l
l
l
l
l
l
Stack strength
l
l
Very high melt flow
l
A consideration for incoming unfilled containers
FDA Requirements
FDA 21 CFR 177 (as per virgin material) applies
l
l
l
l
could be used in middle layer (no direct food contact) if container uses a multi-layer configuration.
Very low melt flow
l
Cross contamination of extrusion and injection resins
l
l
Color, color consistency
l
l
Colors can be darker and/or more yellow due to either contamination in the PCR stream or the resin’s
heat history. Color can tend toward increased brownness if resin is allowed to sit in the dryer. Remove the
reprocessed material as quickly as possible. Adding brighteners may be an option. If color is associated
with a brand, recycled content may simply not be a viable solution. As reprocessing technology evolves,
coloration issues may diminish.
l
No food grade HDPE available
l
Minimal PP PCR available and none is food grade
l
Most municipalities only collect bottles and do not separate PP from PE. At least one converter has
obtained an NOL from the FDA and is currently running organoleptic tests with plans to produce some
food grade containers by end of 2010.
l
15
Household, Care & Laundry
Applications
Product
Miscellaneous
Miscellaneous
EXPLANATIONS / WORK AROUNDS
Laundry Detergent, Fabric Softener and
Laundry Additive
Material and format
Clear PET Bottles Colored Rigid PET Bottles HDPE Bottles
25%
25-35%
25%
High
High
High
UV light barrier
l
l
l
l
l
Using more than 25% PCR content may require some performance trade-offs. Carefully control I.V.
l
l
l
Stress crack resistance
l
l
l
Product formula compatibility
l
l
l
State recycled content requirements
l
l
Regulations regarding required % recycled content my vary by state.
l
l
Compliance depends upon product formulation.
Rate achieved for several years. Technically potential exists to go to 35 - 50%.
FDA Requirements
Compliance with Federal Insecticide, Fungicide and Rodenticide Act
l
l
l
l
Bale quality is deteriorating as more alternative raw material choices come to market. Single stream
recycling contributes to poor quality. Partner with a reliable supplier.
l
l
Light weighting and recycled content use may not be compatible. Blending virgin with the PCR resin can
achieve required IV. Chemical recycling is less likely to affect I.V. as polymer is essentially depolymerized
and remade as virgin. However, achieving effectiveness and efficiency in chemical recycling requires ability
to process materials in quantities of > 50,000 tons/year.
Gels in PCR
l
l
Molding process variability
l
l
l
Critical dimensions variability
l
l
l
Cost of material
l
l
l
Few mechanical recycling technologies can provide a cost advantage over use of virgin resin and the
processes to recycle PET into fiber, strapping, and thermoform are usually less costly than reprocessing
into bottle-grade resin. Mechanical recycling cost efficiency can be achieved at a processing capacity
within a range of 5,000 - 20,000 tons/year.
l
l
l
equipment. Set up appropriate/automated systems, avoid siloing and streamline operations. Securing a
Could cause blow outs or leaks. Partner with a reliable supplier.
Quality suppliers can remove materials with gels by proper sorting.
May affect processing efficiencies or cycle times.
16
Household, Care & Laundry
Applications
Miscellaneous
Laundry Detergent, Fabric Softener and
Laundry Additive
Product
Miscellaneous
Material and format
Clear PET Bottles Colored Rigid PET Bottles HDPE Bottles
l
l
Colors can be darker and/or more yellow due to either contamination in the PCR
stream or the resin’s heat history. Color can tend toward increased brownness if resin is allowed to sit in
the dryer. Remove the reprocessed material as quickly as possible. Adding brighter may be an option. If
color is associated with a brand, recycled content may simply not be a viable solution. As reprocessing
technology evolves, coloration issues may diminish.
Color/color consistency
l
l
l
l
l
Odors
l
l
l
A concern primarily for containers holding unfragranced products.
l
l
l
Pricing fluctuates, so PCR is not always more expensive. Developing long-term but flexible contracts with
suppliers can help to control cost.
l
Typical source is milk bottles.
If clarity or transparency is important PCR may not be viable. If bottle can be colored green or amber, etc.
use of PCR may be more viable because the PCR color and inconsistency are more easily masked.
HDPE bottles have well established infrastructure
l
l
Lack of infrastructure
International competition for PCR material
according to NAPCOR (2008), only 27% of PET bottles are
recycled or approximately 1,451.5 mmlbs. Of the 1,451.5 mmlbs only 141 mmlbs is
recycled to food grade.
l
l
l
Currently no infrastructure to support collection/sorting of highly pigmented bottles; only clear or green.
l
17
Electronics
Applications
Product
Dunnage
Bags
Miscellaneous
Miscellaneous
Material and format
EPS Foam
LDPE Bags
PVC Clam Shells
PET Blister Packs
1-5%
0%
0%
35-50%
Low
Low
Low
Medium-High
Dust barrier
l
l
Moisture barrier
l
l
l
l
l
Anti-static properties
l
l
Vibration resistant (to test levels)
l
l
l
Abrasion protection
l
Heat sealable
l
l
l
l
Potential heat history degradation
l
l
l
l
Can cause black specs and holes or gels. Partner with a reliable supplier.
l
l
Bale quality is deteriorating as more alternative raw material choices come to market. Single stream
recycling contributes to poor quality. Partner with a reliable supplier.
Process cycle time variability
l
l
Can be caused by quality of PCR batch. Partner with reliable supplier and provide detailed specifications.
l
Due to tendency for crystallization or blister stressing.
Theft protection
FDA Requirements
l
l
Cleanliness
l
l
Formation process differences
l
FDA requirements do not apply
Sealing variability
Color, color consistency
l
l
Drop test failure
heat history. Color can tend toward increased brownness if resin is allowed to sit in the dryer. Remove
the reprocessed material as quickly as possible. Adding brighteners may be an option. If color is
associated with a brand, recycled content may simply not be a viable solution. As reprocessing technology
evolves, coloration issues may diminish.
l
l
l
If clarity or transparency is important PCR may not be viable. If bag, clam shell or blister can be colored
green or amber, etc. use of PCR may be more viable because the PCR color and inconsistency are more
easily masked.
Larger tears have been found in recycled foam dunnage than virgin under similar test scenarios.
Limited PCR availability
l
l
l
l
Limited availability is largely due to the lack of recycling infrastructure especially in China where most
electronic packaging is produced.
l
l
l
l
International competition for PCR materials
l
l
l
l
18
Snacks
Applications
Product
Chip bag
Chip bag
“Chip” includes potato, corn and tortilla.
Material and format
Reverse-printed OPP Bags
Metalized OPP Lamented to Reverse Printed OPP Bags
%
0%
Low
Low
Oxygen barrier
l
l
Moisture barrier
l
l
Oil/fat barrier
l
l
Aroma barrier
l
l
Stand up stiffness
l
l
l
l
l
l
requirements as per virgin material. See document text for guidance on petitioning for an NOL. PCR could be
used in middle layer (no direct food contact) since bag is a multi-layer configuration.
Defect free PCR a must
l
l
Due to sensitivity of OPP manufacturing process and need to achieve stiffness and moisture barrier at
thin gauge.
Extreme cleanliness
l
l
Required for metalization and/or print processes.
Costs - material and production
l
l
Integrated recycled content into OPP manufacturing process is possible but not economical.
l
l
If/when PP is clean enough to make OPP, color and color consistency should not be an issue.
Print quality
l
l
If/when PP is clean enough to make OPP, print quality should not be an issue.
l
l
Although collection is increasing, PP is not accepted and/or separated in a majority of recycle streams in
the U.S. Any available PP PCR is currently used in non-food applications.
FDA Requirements
Limited availability of PP
19
Over-The-Counter Pharmaceuticals
Applications
Product
Medicine (e.g., Lozenges)
Toothbrush
Vitamin, Pain
Razor
Medication and Other
Material and format
Copolyester Blister
Packs
PET Blister
Packs
PET Bottles
PET
Clamshells
Vitamins, Pain
Medications and
Other
White HDPE Bottles
0%
<10%
0%
<10%
0%
Low
Medium
Low
Medium
Low
Oxygen barrier
l
l
Moisture barrier
l
l
UV barrier
l
l
l
l
l
l
l
l
l
l
l
l
Product formula compatibility
l
Thermoformable
l
Laminatable
l
l
l
Heat sealable
Die cutable
l
l
l
Sterilization compatibility
l
l
l
l
l
Petition to add material to FDA Materials List for Drugs may be required and process is expensive.
l
could be used in middle layer (no direct drug contact) if container uses a multi-layer configuration.
FDA Requirements
l
l
l
l
l
l
l
l
l
Could affect required barrier properties. Can cause black specs, holes or gels. Metal contaminants could
cause blow outs or leaks. Partner with reliable supplier. Leak detection equipment can be installed.
Formation process differences
l
l
l
l
l
l
l
l
l
l
equipment. Set up appropriate/automated systems, avoid siloing and streamline operations. Securing a
20
Over-The-Counter Pharmaceuticals
Applications
Product
Medicine (e.g., Lozenges)
Toothbrush
Vitamin, Pain
Razor
Medication and other
Material and format
Copolyester Blister
Packs
PET Blister
Packs
PET Pill Bottles
PET
Clamshells
Vitamins, Pain
Medications and
Other
White HDPE Pill
Bottles
l
l
heat history. Color can tend toward increased brownness if resin is allowed to sit in the dryer. Remove the
reprocessed material as quickly as possible. Adding brighteners may be an option. If color is associated
with a brand, recycled content may simply not be a viable solution. As reprocessing technology evolves,
coloration issues may diminish.
Sheet flake has a lower IV than bottle flake so the aesthetic issues related to clarity and transparency or
haziness may be amplified. If clarity or transparency is important PCR may not be viable. If bottle can be
colored green or amber, etc. use of PCR may be more viable because the PCR color and inconsistency
are more easily masked.
l
l
l
l
l
l
l
l
l
Consumers may be more critical of aesthetics related to drug products than other types of products.
l
l
l
l
l
Generally not considered a recycled item
l
l
l
l
Food grade PCR availability is low and regional
l
l
Collection of rigid containers is growing as are initiatives to examine recycling of clamshells and blisters
to sheet flake.
l
l
l
l
l
l
according to NAPCOR (2008), only 27% of PET bottles are recycled or approximately 1,451.5 mmlbs. Of
the 1,451.5 mmlbs only 141 mmlbs is recycled to food grade.
l
Most food grade PET PCR is processed in Eastern U.S. which can add transport costs and GHG
emissions. Support growth of recycling industry in other regions. Very little recycled HDPE is food
grade because PP and PE are generally not separated. However, at least one converter has obtained an
NOL from the FDA and is currently running organoleptic tests with plans to produce some food grade
containers by end of 2010.
21
Applications
Product
Shampoo/
Conditioner
Shampoo/
Conditioner/Soap
Anti-perspirant and
Deodorant Sticks
Liquid
Makeup
Foundation
(makeup)
Mascara
Material and format
HDPE Bottles
PET Bottles
PP Containers
PP Bottles
Copolyester
Jar
HDPE Tubes
25%
25%
0%
0%
0%
Medium
Medium-High
Low
Low
Low
Oxygen barrier
l
l
l
Moisture barrier
l
l
l
l
l
l
l
l
l
l
Stress crack resistance
l
l
l
Dimension critical for product fit
State recycled content requirements compliance
l
l
l
l
Regulations regarding required % recycled content my vary by state.
FDA Requirements
l
l
l
l
Technically an NOL is not required to use PCR in packaging in the U.S., but the material must
meet FDA requirements as per virgin material. See document text for guidance on petitioning
for an NOL. PCR could be used in middle layer (no direct food contact) since bag is a multi-layer
configuration.
l
l
l
l
Could cause blow outs or leaks. Can cause black specs, holes or gels. Partner with reliable
supplier. Leak detection equipment can be installed.
l
l
l
l
Bale quality is deteriorating as more alternative raw material choices come to market. Single
stream recycling contributes to poor quality. Partner with a reliable supplier.
l
l
Gels in PCR
l
l
Molding process variability
l
l
l
Cost of material
l
l
l
l
Few mechanical recycling technologies can provide a cost advantage over use of virgin resin and
the processes to recycle PET into fiber, strapping, and thermoform are usually less costly than
reprocessing into bottle-grade resin. Mechanical recycling cost efficiency can be achieved at a
processing capacity within a range of 5,000 - 20,000 tons/year.
l
l
l
l
equipment. Set up appropriate/automated systems, avoid siloing and streamline operations.
Securing a constant and reliable source or supplier of PCR can minimize complexity.
Light weighting and recycled content use may not be compatible. Blending virgin with the PCR
resin can achieve required IV. Chemical recycling is less likely to affect I.V. as polymer is essentially
depolymerized and remade as virgin. However, achieving effectiveness and efficiency in chemical
recycling requires ability to process materials in quantities of > 50,000 tons/year.
Quality suppliers can remove gels by proper sorting.
l
l
22
Applications
Product
Shampoo/
Conditioner
Shampoo/
Conditioner/Soap
Anti-perspirant and
Deodorant Sticks
Liquid
Makeup
Foundation
(makeup)
Mascara
Material and format
HDPE Bottles
PET Bottles
PP Containers
PP Bottles
Copolyester
Jar
HDPE Tubes
l
l
l
l
l
If clarity or transparency is important PCR may not be viable. If bottle can be colored green or
amber, etc. use of PCR may be more viable because the PCR color and inconsistency are more
easily masked.
l
Odors
l
Colors can be darker and/or more yellow due to either contamination in the PCR stream or the
resin’s heat history. Color can tend toward increased brownness if resin is allowed to sit in the
dryer. Remove the reprocessed material as quickly as possible. Adding brighter may be an option.
If color is associated with a brand, recycled content may simply not be a viable solution. As
reprocessing technology evolves, coloration issues may diminish.
l
l
l
l
l
A concern primarily for containers holding unfragranced products.
l
Pricing fluctuates, so PCR is not always more expensive. Developing long-term but flexible
contracts with suppliers can help to control cost.
l
Typical source is milk bottles
l
l
HDPE bottles have well established infrastructure
l
l
l
l
Majority of recycled PET is converted into polyester fiber, strapping or non-food packaging.
Further, according to NAPCOR (2008), only 27% of PET bottles are recycled or approximately
1,451.5 mmlbs. Of the 1,451.5 mmlbs only 141 mmlbs is recycled to food grade.
l
Limited availability of PP
No viable recycling infrastructure
l
Although collection is increasing, PP is not accepted and/or separated in a majority of recycle
streams in the U.S.
l
l
23

Guidelines for Post Consumer Recycled Content in Plastic Packaging

Transcription

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