On March 2, 2016 industry groups Alliance for Beverage Cartons and the Environment (ACE) and Flexible Packaging Europe (FPE) released a consultation paper on “The need for harmonised EU legislation on food contact materials.” In their paper, ACE and FPE outline the situation for packaging manufacturers regarding the types of food contact materials (FCM) with no EU-wide regulation (i.e. non-harmonized FCMs). In the case of lacking EU-wide regulation, national pieces of legislation are consulted, the report states. However, these are often “limited in scope, outdated or not suitable for the relevant material at hand.” Thus, “this can lead to a situation where materials can be legally placed on the market although there is no legal process for compliance with the food safety principle as these rules are simply missing,” the report further states. The consequences of this situation for packaging manufacturers include handling legislation of 28 different Member States (challenges are e.g. access to legal texts, language barriers), ineffective mutual recognition of different Member State standards, distortion of the internal packaging market in the EU, and loss of consumer trust.

ACE and FPE recommend to further harmonize FCM regulation in the EU. This should include 1) ensuring a level playing field for all types of FCMs, 2) enhancing the scientific knowledge base in order to adequately answer to consumer protection concerns, and 3) “setting a simpler and fully harmonised regulatory framework providing economic actors with more flexibility in employing various tools in ensuring food contact safety and compliance.”

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ACE (March 2, 2016). “The need for harmonised EU legislation on food contact materials.

ACE & FPE (February 2016). “The need for harmonised EU legislation on food contact materials.(pdf)