Everybody knows the final arbiter of prolonged and direct food contact is the FDA food additives act of 1958 sections 404 and 505 section 177.15 20, 175:30, right ?
So why do we need other standards such as USDA, CFIA, AIB or Kosher approval ?
The truth is FDA approved packaging depends on your definition of FDA approved. A little history lesson here: There are two distribution channels for polyethylene resin – “prime” defined as sold direct through major resin producers and “off grade” sold at a lower price through what is known as brokers. Prior to the Reagan administration, only prime resins had FDA certification and traceability. In the 80’s the rules changed. The burden of FDA approval was shifted to the private sector away from the FDA by requiring a chain of certifications from the producer to the end user. The unintended consequence – unscrupulous resellers now certify off grade simply by writing a letter. Voila ! The end user has an FDA letter to cover.
Its worse than you thought. I have confronted FDA officials at conferences and they simply shrug and say they have higher priorities.
Other than USDA certification for bio-based plastics, there is no such thing as USDA approved poly film. Caveat emptor any plastic film supplier who purports to have USDA approved plastic film.
In a multilayer structure, only the layer which comes in contact must be FDA compliant.
CFIA approval is impractical. The film extruder must submit each combination of resins to the Canadian government and hope for approval. Even Nova has not been able to achieve CFIA approval.
While AIB is stringent, the most demanding food grade packaging is Kosher approved. Kosher approval requires due diligence of raw materials and practices by an individual.
Brentwood Plastics does not publish Kosher approval letters for fear of plagiarism.
Based on our experience, Kosher approval is the gold standard.
