The 7th Food Packaging Forum (FPF) workshop on “Improving the chemical safety of food contact articles: Accelerating science and innovation” took place on October 24, 2019, in Zurich, Switzerland. The talk by Mette Holm from the Danish Veterinary and Food Administration (DVFA) of the Ministry of Environment and Food of Denmark provided an overview of the approaches to food contact material (FCM) inspection and control taken by the Danish authorities.

Holm emphasized that “all FCMs must be safe,” covering both “harmonized and partly harmonized material types.” In Denmark, a Declaration of Compliance is required for all types of FCMs (not only plastics). Further, the authorities regularly perform on-site inspections at FCM establishments, which “may result in guidance or more severe sanctions – remarks, enjoining orders, injunctions, prohibitory orders, administrative fines or reporting to the police.” The results of the inspections are public.

DVFA also regularly carries out analytical controls of FCMs, typically choosing up to 4 material types per year, with about 100 samples being analyzed. The latest sampling campaign was focused on per- and polyfluoroalkyl substances (PFAS) in paper and board FCMs and analyzed 30 packaging samples obtained from importers and traders for 24 specific PFAS as well as for total organic fluorine (TOF) content. None of the 24 specific substances could be detected in the migration solutions. However, in 20 out of 30 samples, the TOF was above the background level of 10 µg/dm2. This indicated that the articles likely contained intentionally added PFAS, however, their identities remained unknown.

Holm reminded participants that DVFA had recommended not to use PFAS in paper and board FCM already in 2015 (FPF reported), but since this recommendation was not legally binding, no follow-up could be ordered on the positive samples. Importantly, the legal situation will change from 2020 on, since a “ban of PFAS in FCM of paper and board on the market on its way” following a recent Danish order (FPF reported).

Concluding her talk, Holm provided a few recommendations for “a better future” in the FCM area, including the need for “more focus on FCM control” in EU Member States, a requirement for a “Declaration of Compliance for all material types,” and a “wish for more EU harmonized FCM regulation.” Holm also suggested to consider using “information in the REACH registration, restrictions and authorizations . . .  in the FCM assessment.”

Read more

Mette Holm (October 24, 2019). “Danish FCM inspection and control.” (YouTube; pdf)

DVFA (2019). “PROJEKTER – SLUTRAPPORT. Fluorerede organiske stoffer i pap og papir fødevarekontaktmaterialer (2018).” 2015-29-61-00340 (pdf)