Meaning
Official written confirmation from the food safety regulator indicating that a recycling process is capable of producing food-contact plastic that complies with safety standards. In the plastics recycling industry, a US FDA NOL is sought by recyclers to prove that their decontamination process removes post-consumer impurities to a level that does not pose a health risk. This document allows the recycled resin to be used in food packaging.
The evaluation focuses on the efficiency of the decontamination technology.
Regulatory Compliance
Manufacturers must demonstrate that the recycled plastic meets the same purity standards as virgin resin to be used in contact with food. Receiving a US FDA NOL involves submitting a detailed dossier that outlines the source of the waste plastic and the specific washing, sorting, and decontamination steps. The regulator reviews this information to ensure the process can handle different levels of contamination.
Once issued, the letter acts as a benchmark for quality assurance.
Technical Evaluation
Chemical analysis and challenge tests are used to prove the cleaning efficiency of the recycling equipment. To secure a US FDA NOL, recyclers spike the post-consumer polymer with surrogate contaminants that represent different chemical families. The polymer is then run through the recycling process, and the remaining concentrations of the surrogates are measured.
This test demonstrates the system’s ability to reduce contaminants to safe levels even under worst-case scenarios, giving brand owners the confidence that the recycled material will not leach hazardous substances into their beverages or foods during storage. Detailed records of these challenge tests must be maintained to support ongoing quality audits and process validations.
Commercial Impact
Possession of this regulatory document is essential for recycled resin producers to sell their materials to major brand owners and consumer packaging companies. Having a US FDA NOL allows a recycler to charge a premium for their resin because it is approved for high-value food-contact applications. It also reduces the liability risk for the packaging producer who incorporates recycled content.
Without this letter, the resin is restricted to lower-value industrial or agricultural applications.
