According to the Goverment of Canada news release on February 21, 2023:
Information requirements for evaluating a secondary recycling process
A company requesting a LONO for a food packaging material containing a recycled plastic resin or for a recycling process of plastic materials is required to provide certain information. Health Canada may request additional information after evaluating the information submitted by a petitioner.
Description and proposed use of the finished product including:
- type of the finished product (for example, bottle, film, casing, adhesive)
- dimensions of the product (for example, volume, wall thickness, food contact surface area)
- structure (for example, for laminated films, containers: number of layers, composition of each layer and identification of the food contact layer)
- percentage of the recycled plastic in the finished product
- conditions of use (time and temperature) under which the product will be exposed during packaging, distribution and end use
- types of food that will be in contact with the product
Description of the source of plastic used in the feedstock including:
- information on the plastic source material from PCR feedstock (for example, curbside collection, deposit system, bins, commercial sources, etc.) with particular emphasis on the aspects of traceability and on the actions to prevent entry into the feedstock and articles that are not suitable for food contact applications (for example, industrial plastic containers)
- detailed description of the sorting procedure for the incoming PCR plastic
- quality specifications for the feedstock, which list potential contaminants and their limits. The procedure to evaluate the supplier's ability to meet these specifications should also be provided.
- percentage of non-food use containers in the feedstock. In addition, the petitioner must demonstrate that the potential dietary exposure to chemical contaminants resulting from the non-food use containers must not be higher than 25 ng/kg bw/day from the finished material, using methods defined previously.
Description of the recycling process including:
- a flow chart or other suitable diagram outlining the key steps in the process (for example, input control, sorting, cleaning, drying, grinding or flake production, distribution, recollection)
- detailed description of all the key steps of the process, starting from the input and ending with the recycling plastic, with particular attention given to those steps contributing to removal of potential contaminants from the feedstock (for example, glass, metal, labels, inks)
- identification and characterization of all the chemicals used in the cleaning steps and the possible degradation products of the polymer or of plastics additives
- description of the processing parameters and the relevant steps (for example, temperatures, pressures, flow, times, other operative details, special devices)
- description of the quality control program that will be maintained to eliminate and neutralize chemical and microbial contaminants in the recycled materials
- recycling process efficiency test
Existing authorizations
Manufacturers of recycled plastic are encouraged to provide any information concerning existing authorization by the US Food and Drug Administration (FDA), the European Food Safety Authority (EFSA) or other regulatory organizations.
Contact
Manufacturers of recycled materials wishing to have their products evaluated by Health Canada's BCS on their acceptability for their intended use should address their submissions to:
Food Packaging Materials & Incidental Additives Section
Chemical Health Hazard Assessment Division
Health Canada
251 Sir Frederick Banting Driveway
Postal Locator 2201C
Ottawa ON K1A 0K9
E-mail: fpmia-meaai@hc-sc.gc.ca
