§ 01.4Company / Certifications & Compliance
Reuse is only
responsible if the
paperwork is real.
A reconditioned tote that is not properly tested, labelled and documented is not a sustainability win — it is a liability dressed up as one. Here is exactly what we certify, what we don't, and how to tell the difference.
- UN/DOT
- 31HA1 recertification
- Food contact
- FDA 21 CFR compliant path
- Residues
- RCRA-compliant handling
- QA
- ISO 9001-aligned
§ 01.4.1What we hold and what it covers
Four compliance frameworks, four different scopes.
These are not interchangeable badges. Each one covers a specific thing, and conflating them is how buyers end up with a tote that is legally the wrong container for their product.
UN / DOT
31HA1 recertification
We recertify qualifying composite IBCs for the transport of liquids under 49 CFR and the UN Model Regulations. Recertification covers the container's suitability for transport — not its suitability for your specific product.
- Leakproofness test
- Design-type conformance check
- Marking and re-marking
- Periodic 30-month and 60-month inspection
FDA
Food-contact compliance
Our food-grade path uses bottles manufactured from FDA 21 CFR 177.1520 compliant HDPE, with fully segregated intake, storage, wash water and racking. Documentation travels with every unit.
- Unused or food-only bottle history
- Separated wash circuit
- Separated racking and staging
- Previous-contents chain per unit
RCRA
Residue management
Heels are captured, profiled by compatibility class and consolidated for licensed disposal or recovery. We are explicit about the residue classes we are not licensed to accept.
- Compatibility-class segregation
- Profiling before consolidation
- Licensed outbound only
- Declared exclusion list
QA
ISO 9001-aligned quality system
Our grading scale, wash recipe book, test records and label scheme are maintained as a controlled document set with internal audit. We describe this as aligned rather than certified, because that is the truth.
- Controlled grading definitions
- Per-unit test records
- Wash programme traceability
- Internal audit cycle
§ 01.4.2Honest boundaries
What a recertified tote does not tell you.
This is the part most suppliers leave off their compliance page, and it is the part that causes problems.
| Question | Covered? | Where it is answered |
|---|---|---|
| Will it survive transport? | Yes | Recertification statement |
| Is it leakproof today? | Yes | Per-unit test record |
| Is the marking valid? | Yes | Re-marking record |
| Is it compatible with my chemical? | No | Your own compatibility assessment |
| Is it suitable for food contact? | No | Separate food-grade documentation |
| Is it rated for my packing group? | Partly | Design-type marking — check the full code |
| Will it hold pressure in storage? | No | Composite IBCs are non-pressurised |
Chemical compatibility is always the filler's assessment to make. We supply the container specification and the previous-contents chain; the compatibility decision needs your product data.
Our declared exclusions
We will tell you before a truck is booked rather than after it arrives. We do not accept totes whose declared previous contents include:
- Acutely toxic or P-listed materials
- Radiological or biohazardous residues
- Unstabilised reactive monomers
- Polychlorinated biphenyls
- Anything with an undocumented or unknown fill history on the food-grade path
- 100%
- Reuse units tested
- 30/60month
- Periodic inspection intervals
- 0
- Lot-level grading
- 2paths
- Fully separated wash circuits
No statistical sampling at any volume.
Per UN Model Regulations for composite IBCs.
Every unit is graded individually.
Food-grade never shares water.
§ 01.4.3Documentation
What arrives with your load.
If a receiving QA team cannot reconstruct the history of a unit from the paperwork, the paperwork is decorative. Ours is not.
- Unit label
- Grade · wash programme code · test date · lot number · recertification mark where applicable
- Load manifest
- Per-unit grade breakdown, counts by grade, wash programme per unit
- Previous-contents chain
- Declared fill history per unit, where the originating customer supplied it
- Recertification statement
- UN/DOT 31HA1 statement with test date and inspector reference
- Food-grade pack
- Resin compliance reference, segregation attestation, wash circuit record
- Residue profile
- For inbound loads: compatibility class, profiling result, outbound disposition
Can you recertify totes I already own?
Yes. That is part of our reconditioning service — your assets stay yours, run through the wash and test line, and come back recertified where they qualify.
Why do you say ISO-aligned rather than ISO certified?
Because we are not currently certified, and saying otherwise would be a lie that is easy to check. We run the document control, the records and the internal audit cycle that the standard asks for. If certification matters to your approved-vendor process, tell us and we will talk about the timeline.
Is a reconditioned tote legal for hazardous materials transport?
A properly recertified composite IBC carrying a valid 31HA1 marking is, within its design type and packing group. Whether it is legal for your material also depends on compatibility, concentration and packing group — that assessment is yours, and we will give you every container detail you need to make it.
Do you supply certificates of analysis?
For recycled HDPE flake and pellet, yes — melt index, density, moisture and contamination figures per lot. For containers, the equivalent is the test record and recertification statement.
Vendor onboarding
Send us your approved-vendor questionnaire.
We fill these in regularly and we would rather do it before you need stock than during an outage. Attach it to a request and it reaches our QA lead.