Update on AUTHORIZATION PROCESS FOR PCR-PET
In May 2022, the Taiwan Food and Drug Administration (TFDA) published a guidance on the application process for obtaining an authorization on the recycling process for producing Post-Consumer Recycled (PCR)-PET intended to be used in food containers and packaging in Taiwan. At present, the application for obtaining an authorization for the recycling processes applied to post consumer-PET materials will be opened first, and then other polymeric materials will be evaluated by collecting international standard data on these other recycling processes.
- PET recycled pellets: refers to recycled pellets obtained from the recycling of waste PET plastic food containers, in part or in whole, through a process of cleaning, shredding, melting, decontamination or /and pelletizing, in the form of pellets or chips.
- Decontamination (challenge) test: a test that simulates the presence of chemical contaminants in plastic recycled material that are subjected to a recycling process to confirm the effectiveness of the recycling process with respect to removing contamination.
- Only physical (mechanical) recycling processes are in the scope of this guidance.
- Chemical recycling processes do not require an application to obtain an authorization; however, the food contact materials (FCM) produced by chemical recycling processes need to comply with Taiwan's regulations for food contact materials, such as the ‘Act Governing Food Safety and Sanitation (June 2019) and ‘Sanitation Standard for Food Utensils, Containers and Packages’ (Jan 2023), both issued by the Ministry of Health and Welfare.
- Applicants for "manufacture" and "import" of rPET intended to be used in FCM are different and need to make separate applications.
- Importers or manufacturers with an international certification (e.g., EU, US) are also required to apply for obtaining au authorization.
- When a change in the recycling process or conditions of use is made, a new application is required.
- Registration certificate for recyclable waste treatment industry; • Waste (waste plastic containers) inspection record form;
- Declaration that the source for obtaining the recycled materials is a food container and that the input non-food containers does not exceed 5% (w/w);
- Report for the decontamination (challenge) test;
- The safety assessment of rPET should follow the EU and US safety assessment principles. If applicable, an assessment for infant and child use is required.
Once authorised, the TFDA will provide a Letter of Response (LoR) to the applicant and publish the LoR number, information about the applicant, and the conditions of use on their website. So far, three companies have already been authorized for their recycling processes applied to post-consumer PET materials.
Our experienced Food & Food Contact Materials Team can help you to register your recycling process as well as to prepare the authorization dossier for your recycling processes for PET plastics intended to be used in food contact applications in the Taiwan.