Recycled food-contact packaging: evidence before procurement

Assessment runs from the intended use, not from the material. The specification should state what the packaging will contact, under what conditions of time and temperature, and for how long, because these determine which requirements apply.

A bottle holding a beverage at ambient temperature for months presents a different case from a tray holding a hot product briefly. The material may be the same; the assessment is not.

Writing the intended use down explicitly is the step most often skipped, and its absence is the root of most procurement confusion in this area. Without a stated intended use, there is no defined question for a supplier to answer and no basis on which to judge the evidence they provide.

Having defined the intended use, the evidence requirement becomes specific. Four categories are typically needed, though the precise requirement depends on the case and should be confirmed by someone qualified in food-contact compliance.

Process and supplier identity addresses which recycling process produced the material and who operates it. This matters because authorisation attaches to processes, and a material's suitability depends on how it was produced rather than only on what it contains.

Declarations and statements of compliance address the formal documentation position, including who issued it and what it covers. The scope of a declaration matters: one covering a different intended use does not cover yours.

Supporting evidence and test data address the substantive position. The relevant tests depend on the intended use and on the migration or contamination considerations that apply to it — these are technical matters requiring qualified assessment rather than a checklist.

Evidence has a shelf life. A supplier may change the input feedstock, the process parameters, the line on which material is produced, or the location. Each of these can affect the material's properties even where the recycled content figure is unchanged.

Without an agreed notification route, a business can hold evidence that was correct when issued and is no longer descriptive of what it is being supplied. The specification is in place, the declaration exists, and the material is not the material the declaration was about.

Agreeing a notification obligation at the point of qualification — what changes the supplier must tell you about, and how quickly — is a low-cost control that prevents this. It also gives the business a basis for requiring re-evidence rather than discovering the change through a quality issue.

Three distinct claims get conflated in packaging procurement. Recycled content states how much recycled material is present. Recyclability addresses what happens to the packaging at end of life. Food-contact suitability addresses whether the material is appropriate for the specific use.

They are established by different evidence, issued by different parties, and none implies the others. A material can have high recycled content and be unsuitable for a given food-contact use. A highly recyclable format can be inappropriate for the product. A material suitable for one food contact can be unsuitable for another.

Keeping the three separate in procurement documents, supplier correspondence and internal sign-off is what prevents a certificate for one claim being used to support a decision about another. That separation should be explicit in the specification, because the failure it prevents is invisible at the point it occurs and expensive later.