Food-grade or not: how to tell

Three tests, not one

The bottle's resin. The HDPE has to be a grade cleared for food contact. For polyethylene, FDA lists the olefin polymers that may safely be used in articles that touch food in 21 CFR 177.1520. Bottle makers that make food-contact bottles state which resin they use and that it meets the rule.

The wetted parts. The valve seat, the valve's seals and the cap gasket touch the product too. They need food-contact compounds, and the valve body's plastic or metal has to be suitable as well.

The history. A food-contact bottle that has held a solvent is no longer a food container. A used tote can be food grade only if its history is documented as food from first fill. That is why the used trade grades totes by last contents and asks for the SDS.

How to tell on the tote

You often can't tell from the outside. A natural white bottle looks the same whether its resin is food-contact or not. Check the paperwork: a food-contact statement from the bottle maker that names the resin and the rule, and, for a new tote, the date of manufacture on the bottle matching the cage plate. For a used tote, ask for the last product's SDS and the history document. A tote with neither is non-food-grade for practical purposes.

When non-food-grade is fine

For chemicals, lubricants, cleaning products, non-potable water and anything no person or animal will eat or drink, a food-contact bottle adds nothing. A standard UN-rated tote is the right buy. For livestock water and drinking water, use food-contact totes with no chemical history. CDC's advice for stored drinking water is food-grade containers and never one that held toxic chemicals (CDC).

What food plants add

Your QA programme decides what you need on file. The usual set is the bottle maker's food-contact statement, the gasket materials and the lot or date of the totes received. Some plants also need the fill temperature limit for the bottle, since HDPE softens as it warms. Put all of that on the quote request and we'll include what the maker provides, so you can approve it before ordering. See food-grade totes.

Paperwork a food buyer should keep

A food plant's supplier approval file for totes usually holds three things. The first is a statement from the bottle maker that the resin meets 21 CFR 177.1520 for the intended use (21 CFR 177.1520). The second is the same for the gaskets and any other wetted parts, such as the valve seat. The third is a record that each tote was new or had held only food, and of what. Ask for these with the quote, not after delivery.

Many plants add their own receiving check: the seal on the cap intact, the bottle clean and dry with no odour, the valve closed and capped, the date on the plate recent, and the lot or serial number recorded against the batch it will carry. For foods on FDA's traceability list, plants keep records that follow each lot (FDA, FSMA); noting the tote against the lot makes that easier.

If a tote fails the check, reject it on the delivery paperwork before signing. A tote that has been opened, wetted or stored outdoors without its seal should not go into food service.

Allergens and flavours

A food-contact tote used once and sent on keeps things simple. A tote kept in food service and refilled raises two further questions: allergens, and carry-over of flavour or odour. Plastics can absorb small amounts of strongly flavoured or oily products such as mint, garlic or citrus oils, and release them into the next fill. Keep reusable totes dedicated to one product, or to one allergen profile, and record which.

Short answers

Is a white tote food grade?

Not by its colour. Food grade depends on the resin, the gaskets and the history. Ask for the bottle maker’s food-contact statement.

Can a chemical tote be cleaned for food?

A bottle that has held a non-food product should not go into food service. Use a new food-contact bottle.

What regulation covers food-contact HDPE?

21 CFR 177.1520 lists the olefin polymers, including polyethylene, that may be used in articles that contact food.

Can a food-grade tote go back to food after chemical use?

No. Once a tote has held a non-food product it should stay out of food service, however well it is cleaned.

Is a white bottle always food grade?

No. Colour says nothing about the resin or what the tote held before. Rely on the maker’s statement and the tote’s history, never on appearance.

Are kosher or halal certifications available?

That depends on the bottle maker and your certifying agency. Ask on your request and we will tell you what can be documented.

Do edible oils need a special gasket?

Fats and oils can swell some rubbers over time. Ask for a gasket compound rated for edible oils, and tell us the oil and its storage temperature.

Can food-grade totes be stacked outdoors?

Keep them covered and sealed. Bird droppings, dust and rain on the top opening are a contamination risk when the cap comes off.