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Austrian Research Institute for Chemistry & Technology Interview

Ahead of Global Food Contact 2023, we spoke to Elisa Mayrhofer, Scientist and Project Coordinator at Austrian Research Institute for Chemistry & Technology.

Q. You are speaking about the risk assessment of recycled plastics at this year's conference. Can you give us a snapshot of what delegates will hear?

As part of the European Green Deal all plastic packaging needs to be recyclable or reusable by 2030. In order to meet this ambitious goal, the draft proposal of the "Packaging & Packaging Waste Regulation" defines a mandatory recycled content in plastic packaging for 2030. In the EU currently only one type of food packaging can be recycled back to food contact applications: the PET bottle. The new European recycling regulation (EU) 2022/1616 aims to promote the development of new recycling technologies for other plastic types. However, there are high requirements to provide scientific evidence that these materials are safe, as the European Food Safety Authority currently assumes that any post-consumer contaminant is a SNA-reactive mutagen or carcinogen, resulting in very low safety thresholds. To evaluate, if this worst-case assumption is required, more than 100 mechanically post-consumer recycled polymers were analysed for DNA-reactive contaminants in a joined project by OFI, FH Campus Vienna and the Fraunhofer Institute using chemical trace analysis and in-vitro bioassays. While recycled PET did not show any signs of DNA-reactivity, high levels could be detected in some post-consumer recycled polyolefins by a miniaturized version of the Ames test. The detailed results suggest a systematic contamination formed by degradation reactions during the recycled process which might be related to some printing ink types.

Q. What do you see as the major developments that 2023 will bring regarding food contact regulation, testing and enforcement in general?

In autumn 2022 a new European regulation, (EU) 2022/1616, for recycled plastics in food contact came into force. This regulation introduces the term of novel technologies. While only recycled plastics from approved recycling processes were allowed in direct food contact under the old recycling regulation, the new regulation aims to increase the application of recycled materials for food contact applications. Under certain circumstances including an initial report on their safety, recyclers can place recycled plastics from new technologies, i.e. novel technologies, on the market, even though the safety is not yet confirmed by EFSA. Still, it needs to be guaranteed that the materials comply with Article 3 of the framework regulation, i.e. do not negatively affect consumer health. To generate that much-needed data on recycled plastics, recyclers are required to re-evaluate the safety of their new materials constantly and to publish safety reports every 6 months. These data will be the basis for EFSA's decision about the conversion of a novel technology to a so-called suitable, i.e. authorized or established technology. Even though the new recycling regulation provides a comprehensive overview, still a lot of questions remain open: Which documents need to be included in the initial safety report? Which types of tests need to be applied? Who will decide about the safety? To answer these questions, a European guidance document was already announced and will hopefully help industry in the future.

Q. What are you most looking forward to hearing about and discussing with your fellow speakers and delegates at this year's conference?

Especially in the field of recycling, I see a bit of conflict of interest currently on European level. The European Green Deal aims to promote reused and recycling to fulfil sustainability goals. To enforce that, recently, a draft proposal for the "Packaging & Packaging waste regulation" was published, which foresees minimum levels of recycled content for different types of plastic in food packaging already in 2030, even for plastic types, e.g. recycled polyolefins, where so far not a single recycling technology is considered suitable at a European level. Event though recycling of different plastic types should be promoted by the new recycling regulation, it can take 3 to 7 years until a novel technology is finally converted to a suitable one, i.e. is formally established. This is due to the very strict safety requirements, as EFSA has to make sure to collect enough data to make a profound risk assessment and guarantee consumer health. I am very much looking forward how these two extremes will come together eventually and how different experts of the field evaluate the current situation.