In the beginning of March 2017, the European Food Safety Authority (EFSA) published the latest meeting minutes of its Food Ingredients and Packaging (FIP) Scientific Network on food contact materials (FCMs). The fourth FIP-FCM meeting involved the “Group of interest on coatings” and was held on February 16, 2017 by phone conference.
After the presentations given by the Council of Europe, the European Commission’s (EC) Joint Research Centre, and EU Member States (MS), the meeting participants discussed the differences, commonalities, and challenges regarding the evaluation methods for coatings. All participating MS confirmed willingness to be members of EFSA’s interest group on coatings. The leadership of the group was assigned to the Netherlands. The group will propose an action plan, define objectives, and provide a timeline for the next meetings. According to the meeting minutes, an event report of the meeting, containing further details, will be published at a later stage. A short summary of the presentations is provided here:
The Council of Europe (CoE) reported on its activities on coatings. In 2004 the CoE adopted a resolution on coatings and in 2009 last updated the corresponding Technical Document No.1. The Technical Document contains two lists of monomers and two lists of additives to be used in the manufacture of coatings for food contact. The CoE noted that both the resolution and Technical Document on coatings should be updated to include e.g. guidance on migration testing methods and restrictions for commonly found non-intentionally added substances (NIAS).
The EC’s Joint Research Centre (JRC) presented its baseline study on non-harmonized FCMs (FPF reported). The presentation focused on the area of coatings and reported on national regulatory frameworks specific to this sector. The JRC informed that “excluding substances authorized for use in plastics that are common to Member States, there is little convergence amongst the lists [of substances for coatings] developed at national level or between the national lists and the CoE list.”
MS Slovenia described that “there is no evaluation of substances prior to authorization and no national legislation” regarding coatings in the country. Coatings of samples from official controls are evaluated according to the plastics FCM regulation (EU) No 10/2011 and the CoE’s practical guide for metals and alloys. If concentrations exceed specific migration or release limits (SMLs, SRLs), or if substances are listed as carcinogenic, mutagenic, or reprotoxic (CMRs), exposure assessment is carried out using EFSA’s Comprehensive European Food Consumption Database and performing risk characterization. A recent study by Slovenian scientists measuring the release of titanium dioxide nanoparticles from non-stick frying pans was also presented (FPF reported).
MS the Netherlands informed that its legislation on coatings includes general provisions as well as positive lists of substances to be used for coatings. The legislation covers “all coatings, on any substrate, including these [sic!] on metals and paper and board, but excluding adhesive layers, printing inks, coatings on regenerated cellulose, and coatings not in direct contact with food.” In an upcoming update of the chapter on coatings in the ‘Packaging and Utensils Regulation,’ four types of coatings will be considered: General purpose coatings, solvent-free wax coatings, metallic coatings, and temperature resistant coatings. Separate positive lists will apply for each type of coating and a Declaration of Compliance (DoC) will be needed.
MS Italy explained that coatings are regulated by the Ministerial Decree 21.3.1973 (DM 21.3.73 and amendments), however no specific national guidelines for the safety assessment of coatings are included in the legislation. The EU positive list of substances for plastics ((EU) No 10/2011) and the Ministerial Decree’s positive list of polymers as well as the list of new substances other than those used for plastics are currently considered for coatings. Corresponding overall and specific migration limits (OMLs, SMLs) are applied. Italy further noted that “NIAS are under the responsibility of the business operator who has to perform the risk assessment.”
MS Belgium informed that in September 2016, a Royal Decree on varnishes and coatings intended for food contact was published, describing the substances authorized for intentional use (FPF reported). New substances are subject to evaluation by the Belgian Superior Health Council, however no applications have been received yet. The Decree further lays out the testing conditions for overall and specific migration.
EFSA (March 2017). “EFSA scientific network for the cooperation and harmonization of risk assessment of food contact materials – the ‘EFSA FCM Network’ – Minutes of the 4th meeting – Group of interest on coatings.” (pdf)