Understanding the FDA’s Letter of No Objection (LNO) Process for Recycled Plastics

Annelie Moolman • 24 July 2024

An in-depth look at the FDA’s Letter of No Objection (LNO) process for recycled plastics.

We explore the FDA’s Letter of No Objection (LNO) process for recycled plastics, with insights from Martha Marrapese, an expert with over 30 years in environmental law from Wiley LLP.


The Importance of FDA LNOs

FDA issues LNOs to confirm that recycled plastics meet safety standards for food contact. It’s crucial to note that LNOs are not approvals; rather, they indicate that the FDA has no objections to the use of specific recycled plastics in food packaging. This process is essential for maintaining food safety and promoting a circular economy.


Market Focus and Material Use

Recycled plastics are vital in food packaging. Historically, PET has been the primary material, but HDPE and polypropylene (PP) are gaining prominence. The simplest LNOs to obtain are for virgin materials, while non-virgin materials can also achieve LNOs under specific conditions, despite the increased complexity.


Legislative and Industry Collaboration

The LNO process, developed in cooperation with the industry, aims to encourage the use of recycled plastics. This collaborative effort ensures that recycling methods meet FDA standards, enabling safer and more sustainable packaging solutions.


Conditions and Compliance

LNOs cover various food types and conditions of use, from high-temperature sterilization to frozen storage. Recyclers must ensure their processes comply with stringent FDA standards to obtain LNOs. This compliance is crucial for the safety and efficacy of recycled materials in food applications.


Challenge Testing

For more rigorous conditions, such as high-temperature or fatty food applications, recyclers conduct challenge testing. This involves contaminating virgin resin with a cocktail of substances and processing it through the recycling system to verify safety and effectiveness.


Future Outlook

As the demand for sustainable packaging grows, so does the need for FDA-compliant recycled plastics. Innovations in recycling processes and industry collaboration will drive this growth, ensuring a continuous supply of safe, recycled materials for food packaging.


Conclusion

Understanding the FDA’s LNO process is vital for advancing plastic recycling in the food packaging industry. By meeting stringent safety standards, companies can confidently use recycled materials, supporting a sustainable and safe food supply.


CANEI helps companies and brands integrate recycled raw materials into their products with high-quality rPET, rPP, and rPE. Should you require food-grade recycled plastic raw materials or for more detailed insights, you can reach out to our industry experts at info@canecorp.com.


We hope you found this post insightful and look forward to bringing you more expert knowledge in future entries.

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