On May 6, 2019, the Food Packaging Forum (FPF) submitted comments to the European Commission’s review of the European food contact regulation, in the context of its public consultation (FPF reported). In its position paper, FPF stressed the importance of the regulation to protect public health from exposures to hazardous chemicals migrating from food contact articles. According to a 2016 report by the European Parliament (FPF reported), this core aim of the regulation is presently not being achieved. Therefore, FPF’s position paper points out several aspects with room for improvement, including the overall migration limit of 60 ppm, the functional barrier threshold of 10 ppb, and the molecular weight cut-off of 1000 Da for migrating chemicals not subject to risk assessment. FPF recommends that these practical thresholds are reviewed in the context of modern scientific understanding, and that justifications are provided as to why these limits are set.

Additional challenges for safety assessments are discussed in the position paper, such as the presence of endocrine disrupting chemicals in the overall migrate, mixture toxicity, and the issue of unidentified non-intentionally added substances (NIAS).

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Food Packaging Forum (May 2019). “Position paper by Food Packaging Forum on the European food contact regulation. (pdf)