The plastic challenge
One of the cornerstones of food safety assurance is the requirement that any plastics likely to come into contact with food and food-contact surfaces must be compliant with the associated regulations. In the US, this requirement is generally covered under the applicable FDA’s CFR Title 21 parts 170-189.* In Europe, it is detailed in EC Regulations 10/2011, 1935/2004,. 2023/2006 and 178/2002.
In the US, food contact material compliance can be a complex process. For example, in the case of a plastic material, during its intended usage, if some resin or dye migrated from the material to the food product, then that resin or dye is considered an "indirect additive." It is normally up to the material manufacturer to show that the "indirect additive" and material are safe for intended use in a food facility or establishment rather than the FDA proving that it is safe/unsafe. To be compliant, a material (and hence the "indirect additive") must meet at one or more of the following criteria:
1. Compliant within applicable 21 CFR requirements; or,
2. Generally recognized as safe (GRAS); or,
3. Known to be a prior-sanctioned ingredient; or,
4. Within the threshold of regulations (TOR), which can best be shown through independent migration testing; or,
5. Supported with a valid Food Contact Notification (FCN) number provided by the FDA.
Please note, compliance status of a material must be viewed from the context of "intended use" and also requires food sites to follow GMPs and other applicable food safety practices. Moreover, manufacturers or suppliers of plastics and other such food-contact materials are required to conduct due diligence and keep abreast of prevailing global, regional, federal, and/or state regulations influencing the compliance status of their products in their markets.
The Vikan and Remco products designed for use in contact with food and food-contact surfaces follow these regulations. We include Declarations of Compliance for each of these tools that will tell you how the tool was tested and whether there are any restrictions for its use. They can also be used as proof of food-contact compliance to assure the inspectors, auditors, and customers.
Changes ahead?
The current regulations and limited supply of suitable recycled plastics significantly affect our ability to source cost-effective, recycled plastic raw materials.
The recycled plastics required for our food contact tools (primarily polypropylene) are not currently available for food contact use. Because of this, legally, we must produce its food contact tools from virgin plastic material. However, there is a significant push among industry and regulators to change these requirements in the near future.
Several countries and the EU are working on amending rules so that recycled materials can be used. Essentially, they want the rules to say that if the material was originally food contact compliant, it would continue to be food contact compliant. However, the recycling process itself would have to be validated and verified to ensure this continued compliance.
One area where progress has already been made is in the recycling of food contact PET. This has been driven by its ubiquitous use in beverage bottles and food containers. Food contact compliant recycled polypropylene is not widely available because there is relatively little that makes its way into the recycling stream. Additionally, there has been far less demand from manufacturers for recycled food contact compliant polypropylene. However, this part of the recycling/manufacturing system is rapidly evolving as demand increases.
Read more here
As a member of the Danish Plastics Federation, we closely monitor developments worldwide with the aim of adopting sustainable materials as soon as possible. It is our ambition to have all our plastic products made of recycled or renewable materials by 2030. As we work towards this goal, it is important for us to practice sustainability in other ways.
A step in the right direction
One plastic sustainability initiative that we have already implemented is the production of our Ultra-Slim Cleaning Brush. The block of this brush is made using the virgin, food contact compliant polypropylene offcuts from our other products. It’s just one of the many small steps we are taking on our sustainability journey.
