PET Industry Views On Recycled
Plastics To Food Contact Regulations
Mark Kenrick
Business Director, Artenius PTA Business
Identiplast 2009
April 20th 2009
Contents
•
Why Is Artenius / La Seda Interested In This Topic?
•
PET Manufacturing Industry & The Regulation
•
Background To The Regulation
•
What Recycle Process Is Being Regulated?
•
The Industry Issues With THE EFSA Guidelines
•
Conclusions & Recommendations
•
Summary
Why Is Artenius Interested In These
Regulations?
Leading
position in
the
European
market
z
#1 Integrated PET Packaging Supplier in Europe
z
#1 PET Producer in Europe
z
#1 Preform Producer in Europe
z
#1 PET Recycling Producer in Europe
3
Artenius La Seda Operations 2009
Chemicals
125 ktes pa
Gresford
PET Preforms
Artenius UK
PET&Blending
PTA
Brecht
PET
Preforms/R&D
Bierne
PET Preforms
PTA
Mendig
500 ktes pa
PET Preforms
Beaune
PET Resins
Recycled PET
975 ktes pa
& Preforms
Artenius
Portugal
PET Preforms
PET Resin
345 ktes pa
SUDAMÉRI
CA
Begreen
Artenius
Romania
IQA
Chemicals
PET Preforms
Slir
Orgánic
o
Petroles
t
Artenius
TurkPET
Logístic
s
PET Preforms
Sheet&Film
R-PET
42 ktes pa
Artenius
TurkPET
SINES
PTA
PET Resin
SIMPE
PET
El Jadida
PET Preforms
Artenius Hellas
PET Resin
Artenius San
Roque
PET Resin
Toledo
Artenius Prat
RPB
Artenius Italy
PET Preforms
PET Resin
Recycled PET
PET Resin
PET Manufacturing Industry & The
Regulation
•
PET industry always taken Product Stewardship responsibilities very
seriously
– APME PET created PETCORE which has actively sponsored the growth
in PET recycling since the late 1980s
– Recognised increasing demand from all stakeholders in the value chain
for improved environmental management & sustainability
– Recognised that RPET outlets were reaching saturation and therefore
need to recycle plastics back into food contact packaging applications
•
PET Industry recognised PET as the right candidate to lead recycle back to
food contact
– Only polymer manufactured exclusively to food contact regulatory
standards
– Only polymer with intrinsic ability to be 're-polymerised' easily
•
Identified that within Europe there were little or no harmonised regulations
– some countries even banned the use of recycled plastics in food contact
applications
Regulation Background (1)
•
PlasticsEurope PET Committee decided to drive the need for a
European wide regulation
– Chaired a meeting of EU Industry Associations with an interest in recycle
to food contact applications
– Group proposed a recycle regulation to the EU Commission (DG Sanco)
– Member States and Industry finally agreed a regulation for Europe in
March 2008 (EC) No. 282/2008
•
The regulation laid down a series of rules to allow recycled plastics to
be used to package food
–
–
–
–
Exclusively mechanical recycling
Specifically excludes chemical recycling and in-house scrap
Does not cover recycled plastics behind a functional barrier
Requires that only food contact plastics, used in food contact applications,
may be recycled back to food contact applications
Regulation Background (2)
•
Regulation rules continued
– Requires materials and articles produced from recycled plastics and intended for
food contact to respect the requirements of Article 3 of Regulation (EC) No
1935/2004 (no contamination);
– Requires the use of Good Manufacturing Practice – as laid down in Regulation
(EC) No 2023/2006;
– Requires an effective, audited, Quality Assurance system;
– Requires a change in the Authorisation procedure laid down in Regulation (EC) No
1935/2004;
– Requires the European Food Safety Authority to devise guidelines and carry out
an audit mechanism process to approve complete processes for the recycle of
plastics to food contact applications.
•
The Industry believes the Regulation is clear and serves its purpose (the
purpose industry wanted)
•
However we believe that there are some issues with the EFSA approval
process
What Is The Recycle Process Being
Regulated?
Consumer
Consume
Drink
Industry
Dispose
of
Bottle
Collect
& Bale
Process 1
PET
Bottles
Sort
by material
& colour
Clean Pet
Flake
Flake
Wash
& Dry
Process 2
Treat
Flake
Chemicals
Or SSP
Process 3
Mix
with
VPET
Conversion
Process 4
New
Bottles
Process 5
8
Our Issues With The EFSA Guidelines
•
•
EFSA has proposed a guideline for an audit to approve recycle processes
for plastics to food contact applications
Artenius and the PET Industry perceive there to be positive points and
potential issues with these guidelines
Perceived Issues
Positive Points
Good Science
Data Based
Independent
Lack of clarity versus what is ‘acceptable’
Does not appear to recognise different steps in the value
chain – authorises collectively with no regard to individual
steps & whether they have been previously approved
New installations require full approval with no credit for
technology / previous partial approval
•
What do we mean … ?
What Is The Recycle Process Being
Regulated?
Consumer
Consume
Drink
Industry
Dispose
of
Bottle
Collect
& Bale
Process 1
PET
Bottles
Sort
by material
& colour
Clean Pet
Flake
Flake
Wash
& Dry
Process 2
Treat
Flake
Chemicals
Or SSP
Process 3
Mix
with
VPET
Conversion
Process 4
New
Bottles
Process 5
10
Conclusion & Recommendations
•
Net effect is that as written the guidelines de-incentivise new recycle
plant investment, so we recommend …
•
EFSA recognises that the value chain has 3-5 processes and that
these can be both independent and collective
•
For new technologies
– Provide time-limited approval for individual plants, based on trial & pilot
plant scale processes
– Provide speedy approvals for individual full scale processes when ready
•
For existing technologies
– Simplify the approval process
– Approve individual processes and feedstock streams recognising the part
they play in the whole recycle process
Summary
• The PET Industry wants to be able to meet stakeholder
expectations and maintain the highest level of health, safety &
environmental standards
• The PET Industry wants to see innovation, growth & investment
in the recycling value chain
• The PET Industry positively drove the need for and supports
the Recycle To Food Contact Regulation
• The PET Industry needs EFSA to produce flexible process
approvals to allow this to happen
Thank You