Recycled Content Claims Priced into a Packaging Tax Line
Recycled content tax claims require lot-specific EN 15343 audit trails and migration reports to withstand customs audits and avoid retroactive landed tax liabilities.
FDA NOL
Meaning
Regulatory clearance from the United States Food and Drug Administration verifies the suitability of a recycled plastic for food-contact applications. This clearance, issued as an fda nol, is a document that confirms the agency has no safety concerns regarding the specific recycling process and its output material. It defines the maximum level of recycled content and the types of food that can be packaged.
This letter does not apply to virgin resins or non-food packaging.
Decontamination Verification
Recyclers must submit data from a surrogate challenge test to prove their technology cleans post-consumer resin to an acceptable level. The issuance of an fda nol depends on demonstrating that dietary exposure to residual contaminants remains below the threshold of regulation. This verification is specific to the reactor design and process conditions used during the test.
Material Classification
Recycled polymers are grouped into specific use conditions based on the food types and storage temperatures they can withstand. Having an fda nol allows a molder to blend post-consumer recycled plastic into food-grade packaging. This classification ensures that the recycled material behaves safely under heating or long-term storage.
Market Value
Obtaining this regulatory letter increases the commercial value of recycled resin. Packaging converters pay a premium for certified food-safe post-consumer resin to meet corporate sustainability targets. Uncertified resins are restricted to utility or industrial applications.