Norner and the leading Nordic branded consumer goods company, Orkla Home & Personal Care (OHPC) have joined forces to demonstrate Post-Consumer Recycled (PCR) safety in Personal Care Packaging. The project supports Orkla HPC’s sustainability goal: To use as much recycled material in plastic packaging as safely possible.
This initiative not only aligns with Orkla HPC's internal targets but also anticipates new European Union regulations, such as PPWR Article 7, which will require at least 10% recycled content in contact sensitive packaging by 2030. Furthermore, the project addresses the SDGs #12, which focuses on responsible consumption and production.
Industry Collaboration for Circular Solutions
The project received funding from the Norwegian Retailer’s Environmental Fund (HMF). OHPC contributed industry context and provided the necessary materials, while Norner brought extensive expertise in polymer research and development to qualify for post-consumer recycled (PCR) HDPE for safe use. This collaboration is a practical example of how a branded consumer goods company, and a technology leader can work together to address sustainability challenges without compromising consumer safety.
‘Through our partnership with Norner, we have made significant progress and gained confidence in the safe use of recycled materials in our cosmetic packaging." Kristine Holmqvist, Orkla HPC
New and smarter way to assess PCR safety
Due to the lack of standardized regulations or common criteria regarding PCR quality for cosmetic applications, Norner implemented a comprehensive program of migration testing and risk assessment. This program complies with: - EU 10/2011 food-contact regulations - The recently introduced CosPaTox safety guideline for cosmetic packaging.
The testing protocol involved exposing the packaging to a worst-case simulant, 95% ethanol, for seven days at 60°C. Both targeted and non-targeted chemical analyses were performed to detect any substances migrating from the plastic into the simulant.
This rigorous approach, which matches food-grade safety standards, highlights Norner’s ability to thoroughly qualify recycled materials for such sensitive applications. All analytical results were compared against Specific Migration Limits (SMLs) and evaluated according to toxicological criteria to ensure that consumer safety is never compromised.
‘Consumer safety has always Key Findings been a primary concern for brand owners. This is especially relevant now, as regulations like the PPWR are making the use of post-consumer recycled materials mandatory. Norner leverages its expertise in polymers and material testing to help brand owners worldwide navigate their PCR journey and maintain consumer safety.’ Jorunn Nilsen Principal Researcher Norner
Key Findings
The study involved a comparative analysis of bottles made from 100% virgin HDPE, 100% PCR HDPE, and hybrid designs (including blends of virgin and PCR materials as well as multi-layer constructions).
The main findings are summarized below:
• Higher migration in PCR vs. virgin: Bottles made entirely from recycled HDPE had noticeably more trace substances migrating from them and showed higher overall migration levels than those manufactured from virgin plastic. Among different PCR types, high-quality PCR contained fewer substances and at lower concentrations. Substances like Bisphenol A and a fragrance compound (hexyl salicylate) were found in PCR samples but not in virgin HDPE, highlighting the importance of maintaining strict quality control for PCR materials.
• Effective risk mitigation via material design: Simple modifications to packaging design proved highly effective in reducing migration. For example, blending just 10% virgin HDPE into PCR resin led to a reduction of migrating substances by approximately 60–70% and a decrease in total migration concentrations by 80–90%. Multi-layer bottles with a thin inner virgin layer also served as a functional barrier, preventing most PCR-derived compounds from reaching the product-contact surface.
• Material selection matters: The study showed that selecting a higher-density virgin HDPE for the inner layer offered even better protection. A virgin resin with a density of 0.961 g/cc blocked more migrating substances than a 0.955 g/cc grade, achieving the same barrier performance with a thinner layer. This insight is crucial for designing sustainable packaging that balances barrier properties with required mechanical performance.
• Toxicology review required to support safety: In some PCR materials, certain measured migration levels exceeded regulatory limits. Orkla’s toxicologists conducted a comprehensive risk assessment to evaluate the suitability of different PCR grades for various applications. The assessment shows that—with proper quality controls and risk management, PCR materials can be used safely without compromising consumer health.