January 8, 2019

Compliance Statement for Materials of Construction in Plastic Drums and IBC Products, Greif Packaging LLC, North America

The statements below apply to Greif plastic blowmolded and specialty extruded containers manufactured in North America, including plastic drums and GCube intermediate bulk containers.

FOOD SAFETY. Greif Packaging LLC plastic drums and composite intermediate bulk containers, with exceptions noted in this statement, are made from materials that when reasonably expected to come in contact with the filled product are in compliance with applicable FDA regulations. The filler is responsible for determining the suitability and use limitations of the container and its components, as well as manufacturing process assessment and cleanliness, for the given application. Contact your Greif sales representative to arrange for your evaluation of our manufacturing facilities.

The product contact materials of these containers, as specified to our suppliers, are either generally recognized as safe (GRAS), prior sanctioned, permissible by regulation under the Food Additives Amendment to the Federal Food, Drug & Cosmetic Act (21 CFR), or permissible by Food Contact Notification (FCN).

Virgin high-density high molecular weight polyethylene resin used by Greif Packaging LLC is in compliance with 21 CFR 177.1520. Antioxidants and/or stabilizers for polymers that are proprietary to resin manufacturers are compliant with 21 CFR 178.2010. The recycled material content from our own operations may be in the range of 40%. Such material is internally generated and is suitable for use in food applications. The use of internally generated regrind is consistent with sustainable packaging initiatives.

Non-virgin post-consumer or post-industrial plastic resins do not have a route to FDA compliance. Compliant virgin first use plastic containers from Greif that are being reused do not have a route to FDA compliance and are not authorized by Greif as FDA compliant. The use limitation and suitability of reused materials or containers is the responsibility of the filler.

Plastic drums and IBCs, as made from high-density high molecular weight polyethylene, are also effectively recovered and reused by industrial packaging service providers. Greif offers both closed loop system and end of life services for its plastic products made in North America, through EarthMinded LLC, as part of its sustainability initiatives. For more information, contact your Greif sales representative.

Fill temperatures for plastic drums and IBCs should not exceed 150F. The material of construction in plastic drums and IBCs is capable of test conditions at 0F, using solutions that remain liquid at that temperature.

The useful shelf life of an unfilled plastic drum and IBC is dependent on conditions of storage, UV exposure, top load, and temperature changes that may impact the container performance. The shelf life of an empty plastic drum or IBC, stored out of the sunlight in ambient room temperatures, without top load, is two years. This shelf life position is based on the potential for other uncontrolled storage conditions to affect the exterior integrity of the drum, and this serves as our recommendation. The filler is responsible for inspecting and evaluating the drum for final determination of use.

A specific five year DOT restriction on use and reuse is stated in 49 CFR 173.28(b)(7)(iv)(B). Refer to these reuse regulations of plastic drum packaging with hazardous materials, and specific requirements including leaktesting at 5 years after date of manufacture. This guidance also applies to packaging of non-regulated materials in plastic drums. For GCube intermediate bulk containers refer to 49 CFR 180.351, and specific requirements including leaktesting at 2.5 years after date of manufacture. This guidance also applies to packaging of non-regulated materials in IBCs. The filler is responsible for inspecting and evaluating the drum for final determination of use and reuse.

Colorants, except for non-FDA black and gray, are in compliance with 21 CFR 178.3297. The specific ingredients in the composition are proprietary to Greif; however you can contact your Greif sales representative for samples of resin and colorant for your own internal testing needs. Colorant compositions contain carrier resins that are polyethylene based, and the formulations are typical pigments, minerals and process ingredients as allowed in 21 CFR.

Closures and gasketing systems for closures comply with FDA regulations. Closures are compliant with 21 CFR 177.1520, and gasket compositions are compliant with 21 CFR 177.2600. Vented closures that utilize microporous membranes, i.e. fluoropolymer membranes, do not have a direct route to FDA compliance. Certain vented closures, as designed with splashguards to minimize liquid contact with the vent material, are available for your determination as having a functional barrier between the filled product and the vent material. Other routes to compliance for such vents may include dietary exposure calculations that you can perform for your specific product.

Valves on IBCs, specifically Greif valves, IPCC ball valves, and Banjo ball valves are made from materials that have routes to FDA compliance. Valves made by other vendors are reviewed by component selection. Please contact your Greif representative to have a more detailed discussion about such components.

Contact your Greif sales representative for samples of closure, valve, gasket or vent materials for your own internal testing needs and determinations.

Plastic resins, and above noted colorants and UV inhibitors/stabilizers, used in Greif North America plastic drums and IBCs and as supplied by vendors to Greif, are in compliance to US FDA regulations. Correlation and harmonization of EU Framework Regulation (EC) 1935/2004, GMP Regulation EC 2023/2006, and Plastics Regulation EU/10/2011 (as amended by EU/2017/752) with regulations under US FDA jurisdiction is generally accepted in the United States. Migration testing for determination of use limitations is the responsibility of the filler.

RELIGIOUS REQUIREMENTS. All of the above product contact materials of construction used in the manufacture of plastic drums and composite intermediate bulk containers are not known to have animal derivation, and therefore meet the requirements of Kosher and Halal.

BSE/TSE. All of the above product contact materials of construction used in the manufacture of plastic drums and composite intermediate bulk containers are not known to have animal derivation, and therefore are not anticipated to contain any bovine spongiform encephalopathy agents.

CONEG/CALIFORNIA TOXICS IN PACKAGING. The raw materials of construction for plastic drums and composite intermediate bulk containers are purchased as industry standard materials. Suppliers to Greif have the responsibility to meet the requirements in our specifications for compliance with CONEG Model Legislation, California Toxics in Packaging Legislation, and the Toxics in Packaging Clearinghouse. These requirements include heavy metal sum concentrations not to exceed 100 ppm. Greif does not intentionally add any such substances in its converting process of the raw materials of construction. Compliance with the above Legislation correlates with EU ROHS requirements for heavy metals.

REACH. Greif packaging and containers manufactured in North America are considered articles that are exempt from REACH registration, as there is no intended release or reasonably foreseeable release of any substances used in construction of the articles during the service life of the article. It is the importer of products into REACH countries that has the responsibility to assess and fulfill REACH registration requirements. Greif North America has no further responsibility to address REACH registration requirements.

We are not aware of any substances of very high concern (SVHC’s) in the plastic and IBC products manufactured in North America, with the exception of certain nitrile (Buna) gasket systems. Carpathian and other imported IBC valves may have nitrile gaskets in the body construction. Such gaskets may be derived from phthalates, which are included on the SVHC list. In addition, we do not intentionally add any SVHC’s in our manufacturing process. We do periodically monitor the SVHC list for new entries.

DELETERIOUS SUBSTANCES. Greif is not aware of the presence of, nor do we intentionally add, any of the following substances to our product or include in our process: polycyclic aromatic hydrocarbons (PAHs), quaternary ammonium compounds, melamine, benzophenone, chlorinated compounds, polybrominated biphenyls or polybrominated diphenyls, PVC,PVDC, fumigants, pesticides, preservatives, biocides including dimethylfumarate, perfluorooctane sulfonates or perfluorooctanoic acid, polyfluoroalkyls or perfluoroalkyls, bisphenol A (BPA), phthalates or phthalate esters (including DINP, DIDP, DPHP, DOP, DEHP, BBP, DBP, DIBP, DNOP, DEHP), latex, common food allergens (including peanuts, tree nuts, wheat, fish, crustaceans, soy, milk, eggs).

We are not aware of the presence of carcinogens in raw materials of construction for our plastic drum and IBC products. For more information contact your Greif facility. Greif is not aware of the presence of, nor do we intentionally add, any synthetic fumigants, preservatives, or coatings on the product contact materials of construction, that may transfer to the packaged product.

IBC plastic pallets -Greif is not aware of the presence of, nor do we intentionally add, polybrominated biphenyls and diphenyls, including deca- bromide composition additives, into our product or in the manufacturing process. IBC pallets are available with specific post manufacture treatments or coatings, with special order. Contact your Greif sales representative for more information.

CALIFORNIA PROPOSITION 65. As a result of our manufacturing processes, Greif plastic drums and GCube IBCs do not require any warnings to be made regarding chemicals listed in the California Safe Drinking Water and Toxic Enforcement Act of 1986 (Prop 65).

EU PACKAGING DIRECTIVE 94/62. The above statements apply to the heavy metal requirements of the directive. The filler is responsible for container and component suitability, source separation and recycling/disposal issues in each applicable country of use.

Refer to published terms, conditions of sale, and limitations of liability that govern all sales. Those terms and conditions include all of the above statements. Customers must make their own determination that use of our product is safe, lawful, and technically suitable for their intended application.

Larry Gable Product Technical and Regulatory Support Greif Packaging LLC [email protected]

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