On the final day of the Global Food Contact conference (FPF reported), on June 16, 2021, two talks concentrated on non-intentionally added substances (NIAS) in recycled, bio-based, or biodegradable materials applied in food contact.

Marco Zhong, Director at the National Reference Laboratory for Food Contact Material (IQTC) in Guangdong, China, focused on the regulations of food contact materials (FCMs) made from recycled content applied by East Asian countries. Currently, South Korea and Japan allow the use of some recycled materials in food contact, and Thailand is planning similar policies. China, however, still bans the use of recycled material in the manufacturing of FCMs, but industry stakeholders are trying to speed up approval (FPF reported here and here). Because China considers biodegradable materials environmentally friendly, it allows the use of four material types, including polylactic acid (PLA), in food contact applications if they meet certain safety (e.g., overall migration limit) and voluntary standards (e.g., biodegradability). According to Zhong, one reason for China’s ban of recycled materials in FCMs is that the potential associated risks are not yet fully evaluated. China is particularly concerned about potential NIAS migration into food. Zhong elaborated on China’s efforts in NIAS screening. In an ongoing survey of contaminants in recycled polyethylene terephthalate (rPET) for FCMs, China is applying not only the analytical methods used in the US and EU but additional ones to obtain further information on NIAS. He reported that using different analytical approaches, several NIAS have been detected in rPET intended for food contact applications. The NIAS included degradation products, contaminants, and oligomers as well as substances of high concern.

The next speaker, Marinella Vitulli, director at FCM testing provider Food Contact Center located in Italy, shortly outlined the regulatory guidelines on NIAS in FCMs in Europe and the US. Subsequently, she elaborated on the experimental testing approach to identify NIAS in materials such as rPET. The different steps include targeted and non-targeted analytical methods that consider volatile, non-volatile as well as medium-heavy compounds. In her talk, Vitulli highlighted several challenges in NIAS identification such as the time-consuming nature of the entire process and the difficulty to distinguish NIAS from intentionally added substances. The identification of non-volatile compounds is especially challenging since the libraries needed for it are incomplete. To help address this, the Food Contact Center built a library (SCIEX) that currently lists 9,000 non-volatile substances. By presenting four case studies, Vitulli further visualized the applicability of the previously described testing scheme. For instance, it allows evaluating recycling process efficiency and the quality of the final material or testing biobased materials for potentially toxic compounds.  According to Vitulli, NIAS assessment in recycled plastic is well established but laboratories still need more experience regarding biobased materials. She stressed that the choice of the right analytical approach, e.g., based on the material, is key for NIAS identification.


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Smithers Pira (June 2021). “Global Food Contact 2021.”