Re-migration of reusable packaging

With the current Directive 94/62/EC on packaging and packaging waste and the future revision of the Packaging and Packaging Waste Directive (PPWD), the European Commission has set the goal of reducing or avoiding packaging waste and its impact on the environment and thus ensuring a high level of environmental protection. In addition to the avoidance and recycling of packaging, explicit targets should also enable the reuse and refilling of packaging or articles for multiple use (reuse / multiple applications).

Since 01.01.2023, the reusable offer obligation has also been in force in Germany, which obliges food suppliers to reduce single-use food packaging by offering food and drinks for immediate consumption on site or take-away meals in reusable containers as an alternative to disposable plastic packaging or disposable beverage cups. Despite the intended ecological advantages, reusable packaging also harbors safety concerns.

Reusable packaging intended for direct food contact can absorb substances from the contents (sorption). When reused, these substances can migrate back to the next product (re-migration) and affect its quality and safety. The most common contaminants in plastic packaging include absorbed flavorings and coloring food ingredients from previous uses. The risk of cross-contamination, particularly in the case of misuse with substances and contaminants that are harmful to health, such as heavy metals and household chemicals like detergents and cleaning agents, disinfectants, paints and varnishes, cannot be ruled out. The risk of misuse is increased for reusable packaging if it is not used on site (return systems).

Reusable packaging must also meet the general legal requirements in accordance with Art. 3 of the European Framework Regulation (EC) No. 1935/2004 – including good manufacturing practices. It must be ensured that this does not endanger human health, does not cause any unacceptable change in the composition of the food and does not impair the organoleptic properties of the food.

The research project proposed here deals with the risk assessment of reusable packaging or articles for multiple use (reuse / multiple applications). The focus of this research project is on polyolefin-based packaging and articles that are to be placed on the market as reusable packaging. At present, there is no reliable data available for polyolefin-based reusable packaging on the sorption and re-migration of undesirable substances, which can be introduced in particular through the misuse of these items by the consumer. The planned literature research and the exemplary sorption/re-migration analyses are therefore intended to provide an initial solid data basis for a decision on whether such applications are safe and compliant in terms of preventive consumer protection or allow a risk assessment.