On December 17, 2019, the European Consumer Organization (BEUC) published a position paper on improving the regulation of food contact materials (FCMs) in the European Union. On December 5, 2019, the non-governmental organization CHEM Trust sent a letter to the incoming European Commissioner for Health calling for action to address outstanding concerns related to the chemicals in FCMs.

The BEUC position paper describes the current EU rules on FCMs as “a regulatory relic” and writes that “it is imperative that a reformed EU FCM regime delivers credible answers to known deficiencies, including on non-intentionally added substances, combination effects, and new and emerging risks.” In particular, BEUC calls “for comprehensive, harmonized regulation of all FCMs based on a precautionary approach, combined with a shift in the burden of proof from public regulators to industry, better enforcement and improved information to consumers.”

The organization further referenced and emphasized a previous publication of five key principles for future FCM regulation as developed by a coalition of civil society organizations (FPF reported). The statement also recognized the target set in the recently released EU Green New Deal for all food packaging being reusable or recyclable by 2030 (FPF reported), but it cautions stakeholders to consider the circularity of chemicals in recycling processes and stresses that future regulation must guarantee “the same high level of protection for FCMs made from [both] virgin and recycled materials.” BEUC’s publication provides detailed comments on current regulations, references results from recent studies on chemicals in FCMs carried out by the organization’s members, and outlines recommendations for improving each policy area.

In CHEM Trust’s letter to the European Commissioner for Health, the organization writes that the current legislative system governing FCMs is “inadequate in protecting public health and has been for many years.” It specifically cites concerns related to migration of toxic chemicals into food, lack of harmonized rules for the majority of FCM types, “inadequate safety provisions” that exist for non-threshold substances such as carcinogens and endocrine disrupting chemicals, and the lack of testing requirements for “unknown and potentially toxic non-intentionally added substances” (NIAS). To address these concerns, CHEM Trust also re-emphasized the need for the Commission to follow the previously published five key principles for future FCM regulation (FPF reported).

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BEUC (December 2019). “Time is ripe to repackage food safely: BEUC position on the regulation of Food Contact Materials.” (pdf)

CHEM Trust (December 5, 2019). “Making the European Green Deal deliver: Protect citizens from harmful chemicals in food contact materials.” (pdf)

Chemical Watch (January 3, 2020). “Urgent reform of FCM chemical rules needed, NGO tells EU commissioner.”