‘APK is committed to filling the gap between the quality of recyclates and product requirements and to achieve circularity for packaging’, affirms Klaus Wohnig, CEO, APK AG. Against this backdrop, APK mandated a detailed risk assessment and two toxicological evaluations for its Mersalen LDPE NCY recyclates. The analysis of the random recyclate samples confirmed the higher level of purity and attested to both the fulfilment of REACH requirements and conformity to the provisions set out in the General Product Safety Directive as well as in the Regulation on Cosmetic Products.
Besides PET-recyclates from drinking bottles most recycled plastics do not yet feature food contact approval. And also for cosmetic packaging only few suitable recyclate is available. Requirements are ambitious, as the packaged products do come into direct contact with the human body. If virgin plastics are to be replaced with secondary raw materials, quality standards for the use of recycled plastics in cosmetic packaging need to be defined and implemented through innovative recycling technology.
As a recycling company, APK adheres to waste legislation. However, as a manufacturer of products such as the Mersalen LDPE NCY recyclates, APK also operates within the scope of chemicals and products regulations and provides its clients with a REACH declaration.
Currently, APK uses pre-consumer LDPE/PA multilayer films as input material for the Newcycling process. The renowned testing company Eurofins performed a comprehensive migration analysis based on random samples of Mersalen LDPE NCY recyclates as well as on various pre-consumer input materials. Specific migration tests confirmed that Mersalen LDPE NCY recyclates feature a decisively higher level of purity than recyclates from standard mechanical recycling. For example, the process’ purification step resulted in an over 90% reduction of the impurity caprolactam (contained in the input material). In the different analyses, no significant amounts of substances of very high concern (SVHC) as set forth in REACH EC 1907/2006 were found.
Based on the risk assessment, two human toxicological risk evaluations were performed in 2020 by two independent toxicology experts. The purpose was to evaluate the use of Mersalen LDPE NCY recyclate types for flexible (films) and rigid (bottles) packaging applications for cosmetics such as creams (leave-on scenario) and shampoos (rinse-off scenario) as well as various personal hygiene products (e.g. sanitary towels, wet wipes, diapers, and toilet paper), all in contemplation of use by adults and for children and babies. Both evaluations concluded that Mersalen LDPE NCY recyclates are of appropriate quality and can safely be used for the applications mentioned. Mandatory legal requirements of either a more specific type, such as those for cosmetic products, as set forth in Regulation (EC) No 122372009 on cosmetic products, or the less specific legal obligations contained in the General Product Safety Directive 2001/95/EC, were fulfilled. In addition, the evaluations specified that any health problems or diseases in adults, children, and infants caused by listed non-intentionally added substances could be completely excluded.
‘To strengthen statistical representativity, APK will continue to analyse and develop the purification potential of its advanced physical solvent-based process Newcycling with regard to different pre- and post-consumer materials’, says Hagen Hanel, Head of Research and Development at APK. The ultimate aim is to achieve food contact approval for Mersalen LDPE NCY recyclates in the midterm. APK is involved in several corresponding R&D projects.
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