A DIVISION OF

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Technical Bulletin
PBI 28-1993

RECOMMENDED PRACTICE FOR DOCUMENTATION OF RECYCLED HDPE CONTENT IN

BALED BOTTLES AND RECLAIMED RESIN

1.0 SCOPE the reclaimer in certifying the origin of the

1.1 The purpose of this procedure is to provide a standard
means by which post-consumer HDPE bottles, and the
post-consumer resin made there-from, can be
documented as originating from true post-consumer
sources. As such, what constitutes post-consumer HDPE
is defined and contrasted to what is defined as
post-industrial materials. This will provide a uniform set
of criteria which may be used by bottle producers when
specifying post-consumer HDPE resins for their internal
use.
2.0 SUMMARY OF PRACTICE:
2.1 Procedures and documentation are necessary to ensure
that bottle producers are receiving true post-consumer
resins, regardless of where the resin is purchased. Also,
reclaimers require a standard by which bottle purchases
can be made, assuring that these bottles are
"post-consumer" in nature. By employing the definitions
listed above, documentation can be provided that testify
as to the nature of the feedstock in question. The
principal delineation made between post-consumer and
post-industrial bottles is whether or not the bottle has
been filled with product. If it has, it can be considered
post-consumer, since at that point it is fulfilling its
intended end use of delivering product to the consumer.
These bottles can also be considered as post-consumer
sourced because the recycling of these containers will
serve to divert them from the solid waste stream.
Documentation must be supplied by the collector to the
reclaimer as to the origin of the bottles being delivered.
This will serve as primary documentation to be used by
post-consumer resin to the bottle producer.
3.0 DEFINITIONS
3.1 Post-Consumer Materials-Those products generated by
a business or consumer that have served their intended
end uses, and that have been separated or diverted from
solid waste for the purpose of collection, recycling, and
disposition. The term "intended end use" includes the
distribution, marketing, and use of consumer products.
This definition includes any bottle that has been filled
with product, including those bottles which have been
rejected due to leakage or product spoilage.
3.2 Recovered Material-Materials and by-products that have
been recovered or diverted from solid waste, but not
including those materials and byproducts generated
from, and commonly reused within an original
manufacturing process, as well as those resins that are
reusable after grinding only.
3.3 Recycled Plastics-Those plastics composed of
post-consumer material or recovered material only, or
both, that may or may not have been subjected to
additional processing steps of the types used to make
products such as regrind-recycled, or reprocessed or
reconstituted plastics.
4.0 REFERENCED DOCUMENTS
4.1 ASTM D-5033 "The Development of Standards Relating
to the Proper Use of Recycled Plastics"

To the best of our knowledge the information contained herein is accurate. However, The Society of the Plastics Industry, Inc. assumes no liability whatsoever for the accuracy or completeness of
the information contained herein. Final determination of the suitability of any information of material for the use contemplated, the manner of use and whether there is any infringement of patents
is the sole responsibility of the user.

This test method or practice may involve hazardous materials, operations, and equipment. This test method does not purport to address all of the safety measures associated with its use. It is the
responsibility of the user of this method to establish appropriate safety and health practices and determine the applicability of any federal, state, and local regulatory limitations prior to use.

COPYRIGHT  1993 by THE SOCIETY OF THE PLASTICS INDUSTRY, INC.

PBI 28 - Page 2 of 2
5.0 DOCUMENTATION OF RECYCLED HDPE CONTENT
IN BALED BOTTLES
5.1 The reclaimer shall require documentation from the
bottle collector stating the source of the bottles being
supplied. This documentation will state the
municipality(ies) or other sources from which the bottles
are collected. The collection method must also be
stated, be it curbside pick-up, drop-off centers, materials
recovery facilities, some other collection method, or any
combination thereof. If marketed as post-consumer
bottles, then all bottles must conform to the definition
supplied in this document. The reclaimer shall have
these records on-hand to support subsequent sales of
resin in either pellet or flake form. Recommended
retention of these records is three years.
As stated earlier, the principal delineation made
between post-consumer and post-industrial bottles is
whether or not the bottle has been filled with product. If
it has, it can be considered as post-consumer by virtue
of the fact that it is considered to be fulfilling an
intended end use, that of delivering product to the
consumer. These bottles can also be considered post-
consumer sourced when the recycling of these
containers will serve to divert them from the solid waste
stream.
6.0 DOCUMENTATION OF RECYCLED HDPE CONTENT
IN RECLAIMED RESIN
6.1 With supporting records obtained from the baled bottle
supplier, the reclaimer will certify to the bottle producer
the total recycled HDPE content of the resin supplied.
This can be done in the form of a certification letter or in
conjunction with the certificate of analysis supplied with
every lot. The certification method should be agreed
upon by both reclaimer and bottle producer. If the
reclaimer has been supplied bottles from 100% post-
consumer sources (as defined above) and nothing has
been added to the resin in the form of additives or color
concentrates, then the reclaimer can sell the resin as
100% post-consumer resin. If additives, color
concentrates, or any other substances have been added
to the resin during production other than agents used to
clean the resin, however, a statement must be made to
that effect in the letter of certification/certificate of
analysis. The statement should state the nature of the
material being added to the resin (additive, color, etc.)
and the total loading as a percentage of the total. The
statement need not specify exact ingredients if it is
considered a proprietary formulation. These statements
are needed when bottle producers make recycled HDPE
content claims about their bottle production.