On April 11-12, 2019, the European Plastic Converters Association (EuPC), together with Polymer Comply Europe (PCE), held a Food Contact Plastics Seminar in Brussels, Belgium themed “Improving transparency throughout the supply chain.” The program featured four sessions with speakers from industry consultancies, chemical producers, industry associations, food and packaging companies, and regulatory authorities, including the European Commission (EC).
Rachida Semail from law firm Keller and Heckman presented on the mutual recognition principle within the EU as a valuable tool for marketing food contact materials (FCMs), especially for packaging materials without harmonized EU legislation such as paper and board. Under the principle, an EU Member State may not prohibit the sale on its territory of imported products which are lawfully marketed in another member state. Semail recognized that the principle has not been well received by many industry stakeholders and argues this is largely due to a misunderstanding of the principle and how it functions. She went on to present and discuss revisions that have been made to the principle’s legislation (EU No 515/2019), which are to come into force from April 2020. These changes include the option for business operators to issue a Mutual Recognition Declaration to downstream customers and a problem-solving procedure that did not previously exist.
Lionel Spack from food and beverage company Nestlé presented on approaches for exchanging business to business information with suppliers. One topic of concern Spack highlighted was the presence of non-intentionally added substances (NIAS). He presented research at Nestlé, which found it impossible to predict the presence of NIAS based on measurements of intentionally added substances (IAS). In her presentation, Suzanne De Cort from The Coca-Cola Company made it clear that their organization has started asking suppliers progressively more detailed follow-up questions in order to map relevant information on chemicals that could exist in their packaging.
Geoffroy Tillieux from EuPC also presented work investigating the presence and identification of NIAS in plastic packaging. Together with the EU Joint Research Centre (JRC), laboratory analysis of 71 samples detected the presence of 961 NIAS substances across all tested simulants. Of these substances, the project was able to identify 621 using various methods such as through measuring exact mass. Tillieux highlighted the lack of dedicated substance libraries to assist with consistent identification of NIAS substances across different laboratories. A scientific report summarizing the project is set to be published in the coming months.
To advance improvement of information exchange across the supply chain, Dario Dainelli from PCE presented an ongoing effort to develop a voluntary registry tool for FCMs. The tool is envisioned as an access controlled database allowing actors along the supply chain to store important information and share it with selected business partners. Regulatory authorities would, however, always maintain the rights to access all data. A pilot version of the tool is under development and aims to be completed by the end of the year.
In a session focused on the present regulatory status of FCMs, Takis Daskaleros and Jonathan Briggs from DG SANTE of the European Commission presented on the ongoing evaluation of the EU’s current FCM regulation (FPF reported). The evaluation has involved targeted interviews with member state authorities, surveys for small and medium enterprises, focus group meetings, workshops, and a public consultation open until May 6, 2019 (FPF reported). Briggs commented that a workshop will be held in September 2019 to present the evaluation’s findings. Regarding the topic of recycling for FCMs, the Commission commented that this is an important topic that needs to be regulated properly. Daskaleros called for continued patience while the Commission continues to review this over the next few weeks to months.
In his presentation, Martin Policar from PCE further addressed the topic of regulation for recycling, specifically regarding the ongoing development of an amendment to regulation EU No 282/2008 on recycled plastic materials and articles intended to come into contact with foods. He explained that the amendment plans to introduce specific rules for scraps and offcuts, closed loop processes, chemical recycling, and for the use of functional barriers. It would also introduce mandatory monitoring of plastic contaminants and clarify the obligations for business operators. However, Policar noted that further work on drafting the amendment is currently on hold by the Commission.
EuPC (April 8, 2019). “Final Programme Confirmed – European Food Contact Plastics Seminar 2019.”