Ece Akalin Tugal, a key account manager at APK, confirmed as much. She explained that because of the need for reliable and accurate information in the market regarding whether the recycled materials are safe and suitable for the application the customer is targeting, APK had commissioned a detailed toxicology risk evaluation, that was conducted by an independent toxicology expert.
“Huhtamaki must meet many different specifications,” she said. “What we did was to have an independent third party evaluate whether Mersalen was safe for use as flexible and/or rigid cosmetic packaging- - for use by adults, children and babies.”
The results showed that Mersalen could be safely used in these applications. Moreover, APK is also operating in line with the EU’s product and chemical regulations, which means that it can provide its customers with a REACH declaration, as well, she added.
Food-contact applications not yet feasible
While the purity of the recyclate produced via the Newcycling process is very high, its use in applications such as food-packaging is still a challenge. The reason has more to do with the strict regulations in place in the EU with regard to the use of recycled content for food-contact applications. Currently, the regulations state that only food-contact approved materials may be recycled into food-contact recyclate; an input stream that would be highly limited and difficult to sort and is currently not existent. And while this is a problem for the sorters to solve, it is also one that affects the recyclates produced by APK, said Ece. ”What is probably needed is a closed-loop system. Although the problem there is ensuring a steady and sufficient supply of the particular type of waste packaging needed, especially if demand for the material picks up.”
While the EU Commission would very much like to increase the recycled content of food packaging, the difficulty is how to approach that from safety and input stream perspective, she added. The Directorate-General for Health and Food Safety of the European Commission is studying the possibilities. “So, for the moment we are happy that our material qualifies as suitable for cosmetic applications. And perhaps once these regulations have been reviewed, a legal path will open up to get to food contact applications, such as oral care packaging, as well.”
Huhtamaki has actually already explored the use of post-consumer recyclate derived from just such a closed-loop stream, said Settele. “We used recyclates from a closed milk bottle waste stream to produce tube laminates based on PCR from food packaging. It does also not have full food approval from the European Union, but the resins used have a letter of no objection by American FDA . It was a first step in the right direction. We sampled test material to our European customers from our site in India, but only the future will show whether this is something that can be scaled up or whether we need to wait for European sources to open up.”
Collaboration is essential
“Right now, when it comes to our waste feedstock streams, APK is looking into all options,” said Ece.
APK has already demonstrated that its depolymerisation technology also works for PCR – post consumer recyclate - waste, and not just with the PIR the company currently uses. The company ultimately aim to provide excellent quality from post-consumer mixed plastic waste,”
“We are very focussed on getting the right input, and we have a lot of control over the input at the moment,” she explained. “The solvent-based step means that the technology can handle contaminants more easily than standard mechanical recycling, but the better the input material, the higher quality the output.”
However, in a circular economy, the output ultimately becomes the input again. This means that ideally, the tube laminates produced by Huhtamaki should be turned into recyclable tubes by the tube makers it works with.
“We can produce the best possible recyclable tube laminate – but we can’t help it if the tube maker goes on to cover it with e.g. black print and does not follow the Design for Recycling criteria defined by Recyclass for proper recycling of the tube,” said Jakob.
“The way various departments view the tube is much different from the perfectly recyclable tube envisioned by a project management and Recyclass,” he explained. “Close cooperation and close communication are extremely important; the complete supply chain – complete stream – needs to work closely together in order to align the requirements formulated by Recyclass with the requirements coming from the market.”
Reconciling these very different needs poses a challenge. Huhtamaki has therefore become a member of the RecyClass technical committee in order to gain as much information as possible, said Jakob, and to be able to support its customers regarding the possibilities of the tube laminates it produces.
A major goal for tube makers today is to produce tubes featuring a mono-material structure, ‘including the cap’, he added, which is usually a flip-top in cosmetics packaging. “In the past, these were made from PP, but today, we’re slowly moving towards caps made from PE. It’s yet another step in the right direction. However, for these developments, we must depend on the work of others as they are not in the hands of APK , nor in the hands of Huhtamaki. But for our customers, it is essential that they have the possibility to make their tubes as mono as possible.”
Moving towards commercialisation
The collaboration between Huhtamaki and APK has proved a beneficial one to both until now and the partners see this relationship continuing into the future. To that end, APK is working to achieve commercial volumes of its PIR-based material. It is well on its way: last year saw the scale-up of production to industrial scale, generating enough material to produce one million tubes. Samples were sent to customers to create an awareness of the material. “It’s now up to the market,” said Ece. “But I would say from our end that we are good to go.”
As market demand increases, already a small quantity of these recycled-content tube laminates have been sold. “We are looking forward to seeing our tube projects on the shelves,” said Jakob Settele. Once they are in the supermarket, others might also be inspired to opt for these more sustainable tube laminates as well, he added. Meanwhile, other sustainable directions are also being explored as well
These ambitions are also part of what drives APK forward. As Ece said: “We have shown that we can produce recyclate from post-consumer waste and in the future, we’d like to roll out this technology in future plants. After all, Huhtamaki will need commercial quantities for testing this material. We are looking forward to the construction of a new plant for the production of PCR. In fact, the engineering work has already been completed, so in the coming years we will have a new site where post-consumer household waste will be recycled.” The location of the site will be disclosed at a later date.
The work on the development of PCR is important for another reason as well. As yet, there are no mandatory recycled content targets for tubes, although some brand owners have established their own. Yet, it is likely only a matter of time before these targets are implemented. “We will see the same regulations here as have been enacted in the UK,” said Ece. “We need to work together, to be ready for them, with a material that will not compromise the design specifications or performance of the product.”
And to keep our eyes open to all possibilities, agreed Jakob. “We need to be best prepared for whatever might come up in the future.”
This article first appeared in the May/June issue of Sustainable Plastics.
