On February 28, 2017 a new scientific study entitled “Substances of very high concern in food contact materials: Migration and regulatory background” was published in the peer-reviewed journal Packaging Technology and Science. The authors from the Food Packaging Forum identified 10 substances of very high concern (SVHCs) listed on Annex XIV of the European Chemicals Regulation (REACH) that are also authorized for use in food contact materials (FCMs) and/or appear on FCM inventory lists. The substances comprise four phthalates, two primary aromatic amines (PAAs), three halogenated molecules and one ether-based solvent. Substances listed on REACH Annex XIV are intended for phase out, however FCMs are exempted.

The study’s authors describe the possible application of these substances in the manufacture of FCMs and give evidence, or absence thereof, for migration into food and food simulants. An analysis of peer-reviewed studies and notifications from the Rapid Alert System for Food and Feed shows that FCMs are a source of the four phthalates (diisobutyl phthalate (DiBP, CAS 84-69-5), dibutyl phthalate (DBP, CAS 84-74-2), benzyl butyl phthalate (BBP, CAS 85-68-7) and bis(2-ethylhexyl) phthalate (DEHP, CAS 117-81-7)) and 4,4’-methylenedianiline (CAS 101-77-9) in food. Approaches for evaluating and handling SVHCs under REACH and the European FCM legislation are discussed. Better enforcement of existing legal limits, an explicit ban of SVHCs without specific authorization for use in FCMs and a re-evaluation of previously authorized FCM substances could lower the levels of SVHCs in food.

In February 2017 DiBP, DBP, BBP and DEHP were recognized by the EU Member States of the REACH Committee as human endocrine disruptors (FPF reported). At the time of their inclusion on the SVHC list, all four phthalates had been classified as toxic for reproduction. In 2014, DEHP was additionally recognized to have endocrine disrupting properties in the environment (FPF reported).

On February 13, 2017 the FPF will host a webinar on the topic. Birgit Geueke from the FPF will summarize the main findings of the study and Michael Warhurst, Executive Director of CHEM Trust, will provide further background information on REACH and FCM regulation. More details and a registration form will soon be published on the FPF events website.


Geueke, B. and Muncke J. (2017). “Substances of very high concern in food contact materials: Migration and regulatory background.Packaging Technology and Science (published February 28, 2017).