INSIGHT: Recycled polystyrene wants its place at the table for food-contact applications

LONDON (ICIS)–One of the key challenges for recycled plastics in Europe is gaining the approval for recycled food packaging items to be used into new food packaging items, reducing virgin plastic usage, and creating a closed loop system.

This is something that the well-established recycled polyethylene terephthalate (R-PET) market has done with PET bottles, and to a degree HDPE with milk bottles in the UK but other polymers such as polystyrene (PS), polypropylene (PP) and high- and low-density polyethylene (HDPE, LDPE) have struggled to achieve so far.

PS producer INEOS Styrolution, however, are working to change this and bring mechanically recycled food-contact approved R-PS to Europe in 2025.

The company launched the first large-scale mechanical recycling facility for PS in Krefeld, Germany with partners Tomra and EGN Entsorgungsgesellschaft Niederrhein last year, and has plans for further facilities across Europe.

ECO & Market Development Manager at INEOS Styrolution, Frank Eisentrager,  explained to ICIS why R-PS is the perfect candidate for food-contact applications. He discussed the challenge of getting food approval and how the up-coming EU Packaging and Packaging Waste Regulation (PPWR) could help the R-PS market grow.

THE ‘PERFECT APPLICATION’
One of the largest markets for PS packaging is dairy, and, in particular, yogurt pots.

A key element to yogurt pots or any kind of dairy dessert stored in PS is how it’s stored and its short lifespan.

“The key thing is [the product is] refrigerated and the best before date is relatively short…like 30 days in the fridge [on average], and then it’s back to us as waste”. “It’s the perfect application [for recycling],” Eisentrager says.

Plus, Eisentrager added, both PS and PET are two of the lowest diffusive polymers, meaning the level of migration of the plastic into the content is already low for both, but the refrigeration of the PS pot helps bring that migration level down even further.

Quite a difference to those PET bottles that may sit out on a supermarket shelf or in a household’s cupboard for an extended period.

So, for PS, so far, so good. So why has it taken so long for the first large-scale mechanical recycling R-PS plant to be built?

SECURING FEEDSTOCK
A lot comes down to accessing good quality feedstock PS bales, and that requires encouraging sorting facilities to invest in sorting PS from the mixed waste streams in which it is often found.

Sorting centres tend to focus on ‘higher value’ plastic waste such as PET and polyolefins, with PS slipping through the net and potentially ending up in incineration.

But showing there is value in sorting PS from a waste stream is key.

“You need to pay for the PS because [sorting centres] pay for incineration, so they will be more than happy sorting out PS if they can get any money for it because it avoids them spending money on the interaction,” Eisentrager said.

You also need to make sure there is sufficient feedstock to feed the plants. INEOS’s Krefeld site can process 40,000 tonnes of waste and is strategically located in Germany because the country currently sorts out its PS from other waste streams.

But Germany currently does not produce enough waste PS feedstock to supply the plant, so INEOS will be looking at other sources such as Italy and Poland and Scandinavia which already have some good PS volumes.

There is also the challenge presented by chemical recycling, particularly in France, where PS waste is being sorted for depolymerization, limiting availability for mechanical recycling.

LEGISLATIVE CHALLENGES
One of the major challenges for INEOS, and for all plastics recyclers looking to use recycled plastic in food contact application in the EU, is getting the all-important positive opinion from the European Food Safety Authority (EFSA).

EFSA will only grant a positive opinion if, among other things, 95% of the feedstock plastic waste comes from food-contact applications originally, and that waste has less than 2% contamination – including other plastics and materials as well as organic matter.

Both Styrenics Circular Solutions (SCS), a PS industry body that INEOS is a part of, and INEOS itself have applied for EFSA approval, but the approval process has been delayed because of EFSA’s focus on Regulation EU 2022/1616 on recycled plastic materials and articles intended to come into contact with foodstuffs.

INEOS had to resubmit paperwork under this new Regulation which classes its mechanically recycled R-PS as a novel technology, requiring it to submit data on the recycling technology they use and evidence that the recycled material is safe for food contact applications.

EFSA and the local food safety authority for the country where the facility is located will check production data every six months over a two-year period (though this could potentially extend up to seven years in extreme cases), and once satisfied, will reclassify the novel technology as a suitable technology.

But Eisentrager is confident the approval will pass without problem.

“[To not get positive opinion] for us is hard to think because [the process] is so safe already,” he said. INEOS has been working with the Fraunhofer institute in Germany and lawyers specialised in food contact regulation to ensure the data are complete and positive opinion can be granted, even if they must ‘tune it here and there’ if required by EFSA.

Plus, the company has invested several millions of euros on the facility showing it is truly committed to its success.

But the company is also making sure it covers every eventuality, and should a positive opinion not be granted, then it will continue to use R-PS in the A-B-A structure, whereby the mechanically recycled material is sandwiched between two layers of virgin PS.

This is what the company is currently doing with customers accompanying it on the R-PS journey. But upon receipt of an EFSA positive opinion, INEOS will look to move to making products from 100% R-PS, which Eisentrager hopes will happen during Q2 2025.

GROWTH OPPORTUNITIES
Legislation around recycled plastic and plastic waste is often painted as a challenge to the recycled markets, but it also offers growth opportunities for R-PS.

The draft PPWR currently going through rounds of voting in Europe will set out mandatory recycled content targets for all plastic packaging from 2030.

Some brands and fast-moving consumer goods companies (FMCGs) have already moved away from virgin PS to PET and polyolefins because of the more established recycling infrastructures for those polymers.

Asked whether the new PPWR and its mandatory recycled content targets could help see a resurgence in PS demand, Eisentrager said yes, absolutely.

Proving that PS can be recycled back into food-contact applications means brands and FMCGs can continue to use PS for packaging such as yogurt pots knowing they will have access to sufficient R-PS to meet the PPWR 2030 targets.

Mandating recycled content volumes for packaging producers also removes the argument of cost, as some companies may only use recycled materials if they are competitive in comparison to their virgin counterparts and move away from recycled material if it becomes more expensive.

Some brands also use recycled content because of internal commitments or marketing strategies, but the amount of recycled content can change during periods of market volatility.

WHAT’S THE COST?
The price of recycled plastics can be a very sensitive topic as illustrated by the roller-coaster ride that has been R-PET prices in Europe over the last four years.

Limited feedstock availability, ambitious brand pledges, substitution back to and then away from virgin PET and opportunistic selling have seen R-PET prices across the chain hit record highs and all-time lows within 14 months, but will this be the case for R-PS when it hits commercial scale?

Eisentrager hopes R-PS will not be subject to this volatility as it is still a relatively new market and demand from brands and FMCGs may not be as large as for other polymers such as R-PET, and the conversion costs from the bale to the pellet are also fairly consistent.

But like R-PET, if the price of the feedstock waste rises, especially if demand for recycled material grows, then that could impact the price for R-PS, Eisentrager says.

“If the waste becomes much more expensive then we would pass that through,” he says, adding that in keeping R-PS prices as stable as possible, it may make it more attractive to virgin buyers who ‘hate’ the variability of virgin PS prices in Europe.

Bringing EFSA-positive opinion status to R-PS in Europe would hopefully stem the current move away from PS to other more recyclable polymers. It also shows the waste sector that there is value in collecting and sorting PS, and will encourage more investment in that area.

And with INEOS’ confident attitude towards securing its positive opinion from EFSA and the upcoming mandated recycled content targets for all PS (and other plastic) packaging from 2030, it seems that mechanically recycled R-PS may well be primed and ready to takes its place in Europe’s range of sources of food-contact suitable polymers.

Insight by Matt Tudball