Recycled Plastics in Food Packaging

There is an emphasis throughout the United States on increasing the uses of recycled materials, including plastic. FDA is involved when industry collects used polymeric materials (usually food containers) and proposes to recycle these materials to make new food containers. FDA's main safety concerns with the use of recycled plastic materials in food-contact articles are: 1) that contaminants from the post consumer material may appear in the final food-contact product made from the recycled material, 2) that recycled post-consumer material not regulated for food-contact use may be incorporated into food-contact packaging, and 3) that adjuvants in the recycled plastic may not comply with the regulations for food-contact use. Currently, to address these concerns, FDA considers each proposed use of recycled plastic on a case-by-case basis and issues informal advice as to whether the recycling process is expected to produce plastic suitable for food-contact applications. FDA has prepared a document entitled Guidance for Industry - Use of Recycled Plastics in Food Packaging: Chemistry Considerations that will assist manufacturers of food packaging in evaluating processes for recycling plastic into food packaging.

If a manufacturer would like FDA to consider the use of recycled plastic for a food-contact application, the following information should to be submitted:

1. 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 intended to ensure that only plastic that initially complied with the applicable regulations is recycled. Also, a description of any steps that are taken to ensure that the recyclable plastic is not contaminated at some point, either before collection for recycling, or during the recycling process.
2. The results of any tests performed to show that the recycling process removes possible contaminants. For use of the recycled material as a substitute for plastic made from virgin materials, it would be necessary to either show that there has been no possibility of contamination with substances other than food or to demonstrate, through surrogate contaminant testing and, if appropriate, additional migration testing, that your recycling process successfully removes possible contaminants. However, surrogate contaminant testing is no longer considered necessary to demonstrate that post-consumer recycled (PCR) polyethylene terephthalate (PET) or polyethylene naphthalate (PEN) produced by a tertiary recycling process is suitable for food-contact use. Because FDA has determined that tertiary recycling processes produce PCR-PET or PEN of suitable purity for food-contact use, the Agency no longer sees a need to evaluate tertiary recycling processes for PET or PEN or to issue individual opinion letters for them.
3. A description of the proposed conditions of use of the 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.)

List of Submissions for Which FDA Issued a Favorable Opinion on the Suitability of a Specific Process for Producing Post-Consumer Recycled (PCR) Plastic to be Used in the Manufacturing of Food-Contact Articles.

The table below is a list of submissions for which FDA issued a favorable opinion on the suitability of a specific process for producing post-consumer recycled (PCR) plastic to be used in the manufacturing of food-contact articles. The list includes the date of our "no objection letter" (NOL), the company that made the request, the subject plastic, whether the recycling process is physical or chemical, and limitations on the conditions of use for the recycled plastic. Because the agency is currently developing a formal policy on the use of recycled plastics in contact with food, the decisions set forth in in these opinion letters may need to be modified due to future deliberations on this matter.

For each entry in the table below, there is a hyperlink from the date of the NOL to a redacted copy (in PDF format) of the NOL issued by the FDA.

The Adobe Acrobat reader for PDF files can be downloaded from the Adobe Acrobat Web Site at no charge. For additional help opening and viewing PDF files please consult CFSAN's General Help for Accessing Files page.

Questions pertaining to the use of recycled plastics in food packaging should be directed to the Office of Food Additive Safety ().

Additional Contact Information

No.	Date of NOL	Company	Polymer	Recycling Process	Use Limitations
1	2/21/90 (letter in PDF)	Dolco Packaging Co.	Polystyrene	Physical	Whole egg cartons
2	6/6/90 (letter in PDF)	Covington & Burling	Recycled polymers in general	Not specified	Grocery bags
3	1/9/91 (letter in PDF)	Keller & Heckman on behalf of Hoechst Celanese	PET	Chemical - Regenerated dimethyl terephthalate from depolymerized PET bottles	PET food-contact articles
4	3/13/91 (letter in PDF)	Lewisystems	Polyethylene or Polypropylene	Physical	Harvesting crates for fresh fruits and vegetables
5	4/24/91 (letter in PDF)	Larkin, Hoffman, Daly & Lindgren, Ltd., on behalf of Ultra Pac, Inc.	PET	Physical	Baskets for fresh fruits and vegetables
6	5/23/91 (letter in PDF)	Landfill Alternatives, Inc.	Polystyrene	Physical	Whole egg cartons
7	8/20/91 (letter in PDF)	Keller & Heckman on behalf of Eastman Chemical Co.	PET	Chemical - Regenerated ethylene glycol and dimethyl terephthalate from depolymerized PET bottles	PET food packaging
8	9/3/91 (letter in PDF)	Larkin, Hoffman, Daly & Lindgren, Ltd., on behalf of Ultra Pac, Inc.	PET	Physical	Fresh fruit and vegetable trays
9	12/6/91 (letter in PDF)	Goodyear Tire & Rubber Company	PET	Chemical - PET oligomers from depolymerized PET bottles	PET food packaging
10	3/10/92 (letter in PDF)	Coca-Cola Company	PET	Ethylene glycol as a by-product from manufacturing food grade PET	PET food-contact resin
11	8/21/92 (letter in PDF)	Bullwinkle Partners, Ltd. on behalf of Repak	PET	Physical	Fresh fruit and vegetable baskets and trilaminate clamshell food-contact containers for short-term contact (< 2 weeks) at room temperature or below (interior layer of post-consumer recycled (PCR) PET is separated from food by at least a 1 mil thick layer of virgin, food-grade PET)
12	8/25/92 (letter in PDF)	Larkin, Hoffman, Daly & Lindgren, Ltd., on behalf of Ultra Pac, Inc.	PET	Physical	Nonfood-contact layer in containers for short term storage of food (< 2 weeks) at room temperature or below. The interior layer of PCR PET is separated from food by a layer of virgin, food grade PET 1 mil thick.
13	10/14/92 (letter in PDF)	Keller & Heckman on behalf of DuPont Co.	PET	Chemical - Regenerated ethylene glycol and dimethyl terephthalate from depolymerized post-consumer PET.	PET food-contact articles
14	11/19/92 (letter in PDF)	Lewisystems	Polyethylene and Polypropylene	Physical	Containers for storing refrigerated poultry, red meat, and seafood
15	12/31/92 (letter in PDF)	De Ster U.S. Holding Corp.	Polystyrene	Physical	Nonfood-contact layer of polystyrene airline snack containers used for storing foods for a short period of time (< 2 weeks) and at room temperature or below, providing PCR polystyrene is separated from food by a layer of virgin, food grade polystyrene 1 mil thick.
16	3/1/93 (letter in PDF)	Scientific Certification Systems on behalf of Dolco Packaging Corp.	Polystyrene	Physical	For use in making trays for holding refrigerated meat, providing the PCR polystyrene was previously used for food-contact applications and there is strict source control.
17	4/14/93 (letter in PDF)	Keller & Heckman on behalf of Continental PET Technologies, Inc.	PET	Physical	Non-food contact layer in soft drink bottles at room temperature or below, providing recycled PET is separated from food by a layer of virgin, food grade PET 1 mil thick.
18	6/30/93 (letter in PDF)	Keller & Heckman on behalf of Novacor Chemical, Inc.	Polystyrene	Physical	For manufacturing plates, cutlery, trays, cups, containers, and lids for restaurants, providing there is strict source control of PCR polystyrene that was previously used for food-contact applications.
19	7/1/93 (letter in PDF)	Dolco Packaging Corp.	Polystyrene	Physical	Fruit and vegetable containers, food-service clamshells, and poultry trays, providing there is strict source control.
20	10/21/93 (letter in PDF)	Fabri-Kal Corp.	Polystyrene (crystal and rubber modified)	Physical	Nonfood-contact layer of polystyrene cold drink cups, lids, produce trays, portion cups, and deli food containers, providing PCR polystyrene is from strict sources and is separated from food by a layer of virgin, food grade polystyrene 1 mil thick. Articles are for short term contact (12 days) with food at room temperature or below.
21	12/15/93 (letter in PDF)	Keller & Heckman	PET	Physical	Nonfood-contact layer in packaging for short term storage of food at room temperature or below. The interior layer of PCR PET is separated from food by 1 mil thick layer of virgin, food grade PET.
22	12/20/93 (letter in PDF)	Coca-Cola Co.	PET	Ethylene glycol as a by-product from manufacturing food grade PET	Food-contact PET
23	5/5/94 (letter in PDF)	Keller & Heckman on behalf of Continental PET Technologies, Inc.	PET	Physcial	Non-food contact layer in PET articles for holding aqueous, acidic, and low-alcoholic foods under Condition of Use C (Hot filled or pasteurized above 150 °F) and below, providing recycled PET is separated from food by a layer of virgin, food grade PET 1 mil thick, and the food-contact article is used for storage periods not to exceed one year.
24	6/3/94 (letter in PDF)	Morgan, Lewis, & Bockius on behalf of KAMA Corp.	PET	Physical	Containers for storing fresh fruits and vegetables at room temperature or below.
25	8/3/94 (letter in PDF)	Keller & Heckman on behalf of Creative Forming, Inc.	PET	Physical	Containers for storing fresh fruits and vegetables at room temperature or below, providing PCR PET comes from food-contact articles.
26	8/24/94 (letter in PDF)	Keller & Heckman on behalf of Johnson Controls, Inc.	PET	Physical	Food containers in contact with all types of food under Condition of Use A or below.
27	11/16/94 (letter in PDF)	FP Corp.	Polystyrene	Physical	Nonfood-contact layer of polystyrene containers for short term contact (6-8 hours) with food at 50 °F or below, providing post-consumer polystyrene is separated from food by a layer of virgin, food grade polystyrene 1 mil thick.
28	12/5/94 (letter in PDF)	Keller & Heckman on behalf of Wellman, Inc.	PET	Physical	Containers for storing fresh fruits and vegetables at room temperature or below, providing PCR PET comes from articles used for food-contact applications.
29	2/22/95 (letter in PDF)	Health Products International	High density polyethylene (HDPE)	Physical	Nonfood contact layer of a bottle for packaging dry dietary supplements, providing PCR HDPE is separated from food by a layer of virgin, food grade HDPE 12 mils thick.
30	2/28/95 (letter in PDF)	Keller & Heckman on behalf of Continental PET Technologies, Inc.	PET	Physical	Corrected our letter of 5/5/94 by removing restrictions on conditions of use and time of storage.
31	3/20/95 (letter in PDF)	Flagstar	Polystyrene	Physical	Nonfood-contact layer of polystyrene clam shells and other food service containers, providing PCR polystyrene is separated from food by a layer of virgin, food grade polystyrene 1 mil thick, the PCR polystyrene was previously used for food-contact applications and there is strict source control, and the containers are limited to contact with hot and cold foods for only a few minutes.
32	5/11/95 (letter in PDF)	Keller & Heckman on behalf of Wellman, Inc.	PET	Physical	Nonfood contact layer in containers for limited food contact applications for short term storage periods at room temperature or below, providing recycled PET is separated from food by a layer of virgin, food grade PET 1 mil thick, and the PCR is from reclaimed food-contact articles.
33	7/17/95 (letter in PDF)	Scientific Certification Systems on behalf of ELM Packaging Co.	Polystyrene	Physical	Nonfood-contact layer of polystyrene containers, providing PCR polystyrene is separated from food by a layer of food grade virgin polystyrene 1 mil thick, the PCR polystyrene was previously used for food-contact applications and there is strict source control, and the containers are limited for "fast food" service applications to contact hot and cold foods (i.e., those involving refrigerated or room temperatures or, if higher temperatures are involved, contact is limited to very short time frames).
34	7/3/95 (letter in PDF)	FP Corp.	Polystyrene	Physical	Nonfood-contact layer of polystyrene containers for short term contact (2-3 days) with all food types at 50 °F or below, providing PCR polystyrene is separated from food by a layer of virgin, food grade polystyrene 1 mil thick.
35	8/29/95 (letter in PDF)	Keller & Heckman on behalf of Wellman, Inc.	PET	Physical	Nonfood contact layer in containers for limited food contact applications, providing PCR PET is separated from food by a layer of virgin, food grade PET 1 mil thick, the food-contact article is used for short term storage periods at room temperature or below, and the amount of PCR PET from nonfood applications does not exceed 0.6%.
36	9/25/95 (letter in PDF)	Union Carbide Corp.	HDPE	Physical	Nonfood contact layer in a 2 or 3 layer bottle in contact with dry food with no free surface fat at room temperature or below, providing that the PCR HDPE is separated from food by a layer of virgin, food grade HDPE 4 mil thick, and the PCR HDPE was previously used for food-contact applications.
37	10/12/95 (letter in PDF)	Keller & Heckman on behalf of Hoechst Celanese	PET	Chemical (glycolysis)	PET Food-contact articles
38	11/2/95 (letter in PDF)	Larkin, Hoffman, Daly & Lindgren, Ltd., on behalf of Ultra Pac, Inc.	Crystallized PET (C-PET)	Physical	C-PET cake pans produced from old commercial C-PET cake pans, providing there is strict source control.
39	3/12/96 (letter in PDF)	Keller & Heckman on behalf of Wellman, Inc.	PET	Chemical (glycolysis)	For use in contact with aqueous foods under Condition of Use C or less severe conditions, and fatty foods under Condition of Use D or less severe conditions.
40	3/13/96 (letter in PDF)	Keller & Heckman on behalf of Wellman, Inc.	PET	Physical	For use in contact with aqueous and acidic foods under Condition of Use C or less severe conditions, and fatty and alcoholic foods under Condition of Use D or less severe conditions, providing PCR PET is from food containers collected through a bottle deposit system.
41	4/4/96 (letter in PDF)	Scientific Certification Systems on behalf of Enviroplastics	HDPE	Physical	Produce bags from recycled milk jugs
42	5/1/96 (letter in PDF)	Innovations in PET Pty Ltd.	PET	Chemical (glycolysis)	PET food-contact articles, provided resulting PET complies with 21 CFR 177.1630.
43	5/2/96 (letter in PDF)	Keller & Heckman on behalf of Wellman, Inc.	PET	Physical	For use in contact with dry, aqueous, and acidic foods under Condition of Use C or less severe conditions, and fatty and alcoholic foods under Condition of Use D or less severe conditions, providing PCR PET is from food containers collected through a bottle deposit system and recycled PET complies with 21 CFR 177.1630.
44	7/25/96 (letter in PDF)	Keller & Heckman on behalf of Plastipak Packaging, Inc.	PET	Physical	Non-food contact layer in PET containers for holding foods of all types under Condition of Use C (Hot filled or pasteurized above 150 °F) and below, providing recycled PET is separated from food by a layer of virgin, food grade PET 1 mil thick.
45	10/18/96 (letter in PDF)	Keller & Heckman on behalf of Eastman Chemical Co.	PEN	Chemical - Regenerated dimethylnapthalene dicarboxylate and ethylene glycol from depolymerized PCR poly(oxy-1,2 - ethanediyloxycarbonyl - 2,6-naphthalenediylcarbonyl (PEN) resins using a methanolysis process.	PEN resins for food-contact applications, provided resulting PEN complies with 21 CFR 177.1637.
46	1/17/97 (letter in PDF)	Perstorp Xytec, Inc.	HDPE	Physical	Crates for holding fruits and vegetables at room temperature or below for up to 10 months, providing PCR HDPE is from food-contact articles.
47	1/28/97 (letter in PDF)	Health Products International	HDPE	Physical	Bottles for packaging dry dietary supplements, providing PCR HDPE is obtained from milk jugs.
48	6/6/97 (letter in PDF)	Keller & Heckman on behalf of Wellman, Inc.	PET	Physical	For use in contact with dry and aqueous foods under Condition of Use C or less severe conditions, and fatty foods under Condition of Use D or less severe conditions, providing PCR PET is from food containers collected through a bottle deposit system, and recycled PET complies with 21 CFR 177.1630.
49	6/6/97 (letter in PDF)	Keller & Heckman on behalf of Eastman Chemical Co.	PET	Chemical (glycolysis)	PET resin for food-contact applications, provided resulting PET complies with 21 CFR 177.1630.
50	12/18/97 (letter in PDF)	Scientific Certification Systems on behalf of Enviroplastics	HDPE	Physical	Berry baskets and produce trays, provided PCR HDPE is obtained from milk jugs.
51	1/5/98 (letter in PDF)	Keller & Heckman on behalf of Crown Cork and Seal Co., Inc.	PET	Physical	Articles for contact with aqueous, acidic, and low alcoholic foods (15% or less) under Condition of Use C or less severe conditions.
52	1/16/98 (letter in PDF)	Union Carbide Corp.	HDPE	Physical	For packaging aqueous and/or acidic food under Conditions of Use C through H, providing PCR HDPE is from bottles used in food-contact applications.
53	7/21/98 (letter in PDF)	Keller & Heckman on behalf of Continental PET Technologies, Inc.	PET	Physical	Non-food contact layer in PET bottles for holding high-alcoholic and fatty foods under Condition of Use D (Hot filled or pasteurized below 150 °F) and below, providing recycled PET is separated from food by a layer of virgin, food grade PET 1 mil thick, and the food-contact article is used for storage periods not to exceed one year.
54	10/2/98 (letter in PDF)	Pure Tech Plastics, Inc.	PET	Physical	Articles for contact with aqueous, acidic, low alcoholic (8% or less), and dry foods at room temperature (120 °F) or below.
55	12/29/98 (letter in PDF)	Keller & Heckman on behalf of Clean Tech, Inc.	PET	Physical	Articles for contact with all types of food under Condition of Use A (High temperature heat -sterilized (e.g., over 212 °F)) and less severe conditions.
56	12/29/98 (letter in PDF)	Dolco Packaging Corp.	Polystyrene	Physical	Fruit and vegetable containers, food-service clamshells, and meat and poultry trays, providing the recycled polystyrene is obtained from pre-consumer sources and there is strict source control.
57	4/13/99 (letter)	Fraunhofer Institut Verfahrenstechnik und Verpackung on behalf of OHL Apparatebau & Verfahrenstechnik GmbH	PET	Physical	Articles for contact with all types of food at room temperature (120 °F) or below, providing PCR PET comes from food-contact articles, and the recycled PET complies with 21 CFR 177.1630.
58	8/10/99 (letter in PDF)	Keller & Heckman on behalf of Phoenix Technologies, L.P.	PET	Physical	Articles for contact with dry (no surface fat or oil), aqueous, acidic, and low-alcohol (<15%) foods at room temperature and below, provided the pcr pet comes from containers previously used for food and non-food applications (excluding industrial pet containers) obtained from deposit and curbside recycling programs, and the recycled pet complies with 21 177.1630.
59	8/10/99 (letter in PDF)	Keller & Heckman on behalf of Phoenix Technologies, L.P.	PET	Physical	Articles for contact with dry (no surface fat or oil), aqueous, acidic, and low-alcohol (<15%) foods at room temperature and below, provided the pcr pet comes from containers previously used for food and non-food applications (excluding industrial pet containers) obtained from deposit and curbside recycling programs, and the recycled pet complies with 21 177.1630.
60	2/1/00 (letter)	Keller & Heckman on behalf of United Resource Recovery Corp.	PET	Physical	Articles for contact with dry (no surface fat or oil), aqueous, acidic, and low-alcohol (<15%) foods at room temperature and below, provided the pcr pet comes from containers previously used for food and non-food applications (excluding industrial pet containers) obtained from deposit and curbside recycling programs, and the pcr pet complies with 21 177.1630 or 177.1315.
61	2/3/00 (letter)	Morgan, Lewis & Bockius on behalf of Ivex Packaging Corp.	PET	Physical	Nonfood-contact layer in packaging for applications at room temperature or below. The interior layer of PCR PET is separated from food by 1 mil thick layer of virgin, food grade PET.
62	8/1/00 (letter)	Polystyrene Recycling Company of America	Polystyrene	Physical	For manufacturing trays for holding refrigerated meat/poultry, fruit/vegetable containers and food-service clam shells, providing the PCR polystyrene was previously used for food-contact applications and there is strict source control. Additionally, the PCR polystyrene may be used as the blending component of a nonfood-contact layer of polystyrene containers, plates, and cutlery, providing PCR polystyrene is separated from food by a layer of virgin, food grade polystyrene 1 mil thick, the PCR polystyrene was previously used for food-contact applications and there is strict source control, and the articles are limited for "fast food" service applications to contact hot and cold foods (i.e., those involving refrigerated or room temperatures or, if higher temperatures are involved, contact is limited to very short time frames).
63	8/23/00 (letter)	Keller & Heckman on behalf of Eastman Chemical Co.	PET	Chemical (glycolysis/methanolysis)	Articles for contact with all types of food, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630 or 177.1315.
64	11/17/00 (letter)	Fraunhofer Institute for Process Engineering and Packaging on behalf of EREMA Plastic Recycling Systems	PET	Physical	Articles for contact with all types of food at room temperature and below, provided the PCR PET comes from containers previously used for food applications obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630.
65	4/20/01 (letter)	Keller and Heckman on behalf of Plastic Technologies, Inc.	PET	Physical	Articles for contact with dry (no surface fat or oil), aqueous, acidic, and low-alcohol (<15%) foods under conditions of use B-H, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial pet containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630.
66	6/1/01 (letter)	Visy Plastics Pty Ltd.	PET	Physical	Articles for contact with dry (no surface fat or oil), aqueous, acidic, and low-alcohol (<15%) foods at room temperature and below, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial pet containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630.
67	6/7/01 (letter)	Fraunhofer Institute for Process Engineering and Packaging on behalf of EREMA Plastic Recycling Systems	PET	Physical	Articles for contact with all types of food at room temperature and below, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630.
68	6/13/01 (letter)	Fraunhofer Institute for Process Engineering and Packaging on behalf of Buhler AG.	PET	Physical	Articles for contact with with all types of food under Condition of Use C and less severe conditions, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630.
69	8/28/01 (letter)	Evergreen Partnering Group Inc.	Polystyrene	Physical	For manufacturing food-contact articles to be used by cafeterias in institutions such as colleges, schools, hospitals, and jails, providing there is strict source control of PCR polystyrene that was previously used for food-contact applications.
70	9/20/01 (letter)	Center for Regulatory Services on behalf of AIES Company, Ltd.	PET	Chemical (glycolysis)	PET food-contact articles
71	12/18/01 (letter)	Keller & Heckman on behalf of NanYa Plastics Corp.	PET	Chemical (glycolysis)	PET food-contact articles
72	12/21/01 (letter)	Keller & Heckman on behalf of Teijin Limited	PET	Chemical (methanolysis)	PET food-contact articles
73	6/26/02 (letter)	Signum	PET	Physical	Nonfood-contact layer in packaging for applications at room temperature (120 °F) or below. The interior layer of PCR PET is separated from food by 1 mil thick layer of virgin, food grade PET.
74	1/28/03 (letter)	Recipet and Typack	PET	Physical	Containers (e.g., clamshells, trays, and baskets) for short term storage (up to several weeks) of fresh fruits and vegetables at room temperature (120 °F) or below, provided the PCR PET comes from PET soda and juice bottles obtained from deposit and curbside recycling programs.
75	1/28/03 (letter)	Keller & Heckman on behalf of Wellman, Inc.	PET	Physical	For use in contact with dry, aqueous, and acidic foods under Condition of Use C or less severe conditions, and fatty and alcoholic foods under Condition of Use D or less severe conditions, provided the PCR PET comes from containers obtained from deposit and curbside recycling programs, and the recycled PET complies with 21 CFR 177.1630 and any other applicable regulations.
76	2/10/03 (letter)	Fraunhofer Institute for Process Engineering and Packaging on behalf of EREMA GmbH	PET	Physical	Articles for contact with all types of food for hot fill applications above 150 °F or less severe conditions, provided the PCR PET comes from containers previously used for food and/or non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630 and any other applicable regulations.
77	2/10/03 (letter)	Fraunhofer Institute for Process Engineering and Packaging on behalf of AMCOR Twinpak - North America Inc.	PET	Physical	Articles for contact with all types of food for hot fill applications above 150 °F or less severe conditions, provided the PCR PET comes from containers previously used for food or non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630 and any other applicable regulations.
78	2/21/03 (letter)	Keller & Heckman on behalf of Mitsubishi	PET	Chemical (methanolysis)	PET food-contact articles
79	3/17/03 (letter)	Fraunhofer Institute for Process Engineering and Packaging on behalf of OHL Apparatebau & Verfahrenstechnik GmbH	PET	Physical	Articles for contact with all types of food at room temperature (120 °F) and below, provided the PCR PET comes from containers previously used for food and/or non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630 and any other applicable regulations.
80	3/26/03 (letter)	Fraunhofer Institute for Process Engineering and Packaging on behalf of OHL Apparatebau & Verfahrenstechnik GmbH	PET	Chemical (glycolysis)	PET food-contact articles
81	5/22/03 (letter)	Roychem	PET	Chemical (glycolysis)	PET food-contact articles
82	6/30/03 (letter)	Fraunhofer Institute for Process Engineering and Packaging on behalf of OHL Apparatebau & Verfahrenstechnik GmbH	PET	Physical	Articles for contact with food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630.
83	8/14/03 (letter)	Keller & Heckman on behalf of Pure Tech Plastics	PET	Physical	Articles for contact with food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630.
84	11/18/2003 (letter)	Keller & Heckman on behalf of Plastic Technologies, Inc	PET	Physical	Articles for contact with food under Conditions of Use B through H, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630.
85	12/30/2003 (letter)	Fraunhofer-Institut für Verfahrenstechnik und Verpackung on behalf of ERMA GmbH	PET	Physical	Articles for contact with food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630.
86	6/4/2004 (letter)	OFI Technologie & Innovation GmbH on behalf of STARLINGER & Co. GmbH	PET	Physical	Articles for contact with food under Conditions of Use E through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630.
87	6/4/2004 (letter)	Fraunhofer-Institut für Verfahrenstechnik und Verpackung on behalf of Se.Ri.Plast. s.r.l.,	PET	Physical	Articles for contact with shell eggs and fresh fruit and vegetables that would be peeled or washed before consumption under Conditions of Use E through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630.
88	7/9/2004 (letter)	Fraunhofer-Institut für Verfahrenstechnik und Verpackung on behalf of Sipa s.p.a.	Urethane-Acrylate	Physical	Use as nonfood-contact layer of PET bottles will not effect recyclability of such bottles by conventional or "superclean" methods.
89	7/13/2004 (letter)	Keller & Heckman on behalf of Pure Tech Plastics	PET	Physical	Articles for contact with food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630.
90	9/9/2004 (letter)	Visy Industries	PET	Physical	Articles for contact with food under Conditions of Use E through G, as well as for contact with dry (no surface fat or oil), aqueous, acidic, and low-alcohol content foods under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630.
91	12/29/2004 (letter)	SIGNUM	PET	Physical	Nonfood-contact layer in packaging for applications at room temperature (120 °F) or below, provided the PCR-PET comes exclusively from containers previously used for food and the PCR PET is separated from food by 1 mil thick layer of virgin, food grade PET.
92	1/25/2005 (letter)	Keller & Heckman on behalf of Mitsui Chemicals Inc	PET	Physical	Articles for contact with aqueous, acidic, and low-alcohol content foods under conditions of use B through H provided the PCR PET comes exclusively from containers previously used for food obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630.
93	2/17/2005 (letter)	Keller & Heckman on behalf of United Resource and Recovery Corporation	PET	Physical	Articles for contact with food under Conditions of Use B through H, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs, and the PCR PET complies with 21 CFR 177.1630.
94	7/20/2005 (letter)	Keller & Heckman on behalf of Sidel Inc	Hydrogenated Carbon		Food contact layer applied at a minimum thickness of 0.065 microns for use with PET resin consisting of up to 50 % PCR PET under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) obtained from deposit and curbside recycling programs.
95	3/15/2005 (letter)	Keller & Heckman on behalf of United Resource Recovery Company (URRC)	PET	Physical	Articles for contact with all types of food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications, and the PCR PET complies with 21 CFR 177.1630 and 177.1315.
96	5/25/2005 (letter)	Keller & Heckman on behalf of Eastman Chemical Co.	PET	Chemical (glycolysis)	PET Food-contact articles.
97	10/26/2005 (letter)	Keller & Heckman on behalf of Toyo Seikan Kaisha, Ltd.	PET	Physical	Nonfood-contact layer in packaging for applications under Condition of Use C and below, provided the PCR PET is separated from food by ≥ 2 mil thick layer of virgin, food grade PET, and the PCR PET complies with 21 CFR 177.1630.
98	1/13/2006 (letter)	Keller & Heckman on behalf of Plastic Technologies, Inc. (PTI)	PET	Physical	Articles consisting of up to 50%  PCR PET for contact with all types of food under Conditions of Use B through H.
99	4/27/2006 (letter)	Packaging Development Resources (PDR)	Polystyrene	Physical	For manufacturing food-contact articles to be used in fast-food and similar restaurants, provided the PCR polystyrene was previously used for food-contact applications and there is strict source control.
100	6/15/2006 (letter)	Fraunhofer-Institut  Verfahrenstechnik und Verpackung on behalf of SIPA SpA	PET	Physical	Articles for contact with all types of food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications.
101	10/10/2006 (letter)	Fraunhofer-Institut  Verfahrenstechnik und Verpackung on behalf of  Rethmann Plano	PET	Physical	Articles for contact with food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications.
102	11/28/2006 (letter)	Fraunhofer-Institut  Verfahrenstechnik und Verpackung on behalf of KRONES AG	PET	Physical	Articles for contact with food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications.
103	12/6/2006 (letter)	Fraunhofer-Institut  Verfahrenstechnik und Verpackung on behalf of Waste and Resource Action Program (WRAP)	PET	Physical	Articles for contact with food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications.
104	12/26/2006 (letter)	Fraunhofer-Institut  Verfahrenstechnik und Verpackung on behalf of UOP	PET	Physical	Articles for contact with food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications.
105	12/26/2006 (letter)	Merlin Plastics Alberta, Inc.	PET	Physical	Articles (e.g., clamshells) for contact with raw fruits and vegetables and shell eggs, for short periods of time at room temperature or below (e.g. Conditions of Use E through G), provided the PCR PET comes from food and beverage containers collected through a bottle deposit system (excluding non-food PET containers and industrial PET containers).
106	1/31/2007 (letter)	Fraunhofer-Institut für   Verfahrenstechnik und Verpackung on behalf of SIPA s.p.a.	Epoxy and acrylic-based polymers	Physical	Use as nonfood-contact layer of PET bottles will not effect recyclability of such bottles by conventional or "super clean" processes.
107	1/31/2007 (letter)	Fraunhofer-Institut für Verfahrenstechnik und Verpackung on behalf of Plastlac Srl	Acrylic polymers	Physical	Use as nonfood-contact layer of PET bottles will not effect recyclability of such bottles by conventional or "super clean" processes.
108	4/20/2007 (letter)	Fraunhofer Institut Verfahrenstechnik und Verpackung on behalf of Waste and Resource Action Program (WRAP)	HDPE	Physical	Articles consisting of up to 50% PCR HDPE for contact with fresh milk  under refrigeration temperatures (i.e. Condition of Use F), provided the PCR HDPE comes from milk bottles only.
109	5/23/2007 (letter)	Global P.E.T., Inc.	PET	Physical	Articles (e.g., clamshells) for contact with raw fruits and vegetables and shell eggs, for short periods of time at room temperature or below (i.e. Conditions of Use E through G), provided the PCR PET comes from food and beverage containers (excluding non-food PET containers and industrial PET containers) and the PCR PET complies with 21 CFR 177.1630.
110	6/25/2007 (letter)	Fraunhofer Institut Verfahrenstechnik und Verpackung on behalf of Uhde Inventa-Fisher GmbH & Co. KG (UIF)	PET	Physical	Articles consisting of up to 50% PCR PET for contact with all types of food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) and the PCR PET complies with 21 CFR 177.1630.
111	8/27/2007 (letter)	Fraunhofer Institut Verfahrenstechnik und Verpackung on behalf of SIG Corpoplast GmbH & Co. KG (SIG)	Silicon Oxide		Food contact layer applied at a thickness of 100 nanometers for use with PCR PET for contact with aqueous, acidic and low alcoholic beverages (< 8% alcohol content) under  Conditions of Use E through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) and the PCR PET complies with 21 CFR 177.1630.
112	9/12/2007 (letter)	UltrePET, LLC	PET	Physical	Articles for contact with aqueous and dry foods under Conditions of Use C through G, and fatty foods under Conditions of Use D through G, provided the PCR PET comes from containers previously used for food and beverages  obtained from deposit recycling systems, and the PCR PET complies with 21 CFR 177.1630 and other applicable regulations.
113	10/22/2007 (letter)	Preformia Oy	PET	Physical	Articles for contact with all types of food under Conditions of Use E through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) and the PCR PET complies with 21 CFR 177.1630.
114	10/29/2007 (letter)	Fraunhofer Institut Verfahrenstechnik und Verpackung on behalf of Starlinger & Co. Gesellschaft m.b.H. (Starlinger)	PET	Physical	Articles for contact with all types of food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) and the PCR PET complies with 21 CFR 177.1630.
115	2/14/2008 (letter)	Fraunhofer Institut Verfahrenstechnik und Verpackung on behalf of 4PET Recycling B.V.	PET	Physical	Articles for contact with all types of food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) and the PCR PET complies with 21 CFR 177.1630.
116	2/26/2008 (letter)	Fraunhofer Institut Verfahrenstechnik und Verpackung on behalf of Starlinger & Co. Gesellschaft m.b.H. (Starlinger)	PET	Physical	Articles for contact with all types of food under Conditions of Use C through G, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) and the PCR PET complies with 21 CFR 177.1630.
117	7/30/2008 (letter)	Keller & Heckman on behalf of Plastic Technologies, Inc.(PTI)	PET	Physical	Articles for contact with all types of food under Conditions of Use B through H, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) and the PCR PET complies with the existing applicable authorizations.
118	11/21/2008 (letter)	Keller & Heckman on behalf of ECO2 Plastics	PET	Physical	Articles for contact with all types of food under Conditions of Use A through H and J, provided the PCR PET comes from containers previously used for food and non-food applications (excluding industrial PET containers) and the PCR PET complies with the existing applicable authorizations.