On January 11, 2023, the Food Packaging Forum (FPF) submitted comments to the European Commission’s Directorate General for Health (DG Sante). DG Sante had requested input on its ongoing revision of EU rules on food contact materials (FCMs) (FPF reported).
In its response to DG Sante’s survey, FPF clarified that the scope of new FCM rules should be for “any and all materials and articles that are intentionally brought into contact with foodstuffs”, with the exception of articles regulated elsewhere (e.g. drinking water pipes). FPF also stresses that there is a need for better informing specific FCM users about the risk of chemical migration from repurposed materials for food contact use (such as bubble wrap or beer cans that are used in creative cooking recipes).
Further, FPF’s comments highlight the need to align FCM regulation with other EU strategies and rules regarding sustainability, for example relating to how foodstuffs are produced or how packaging waste is managed. Importantly, there is a great need for ensuring that recycled materials are truly safe, meaning that they do not contain hazardous or untested chemicals. This important requirement is currently not fulfilled and, as a result, public health is at risk.
The safety definition for virgin FCMs should also be amended. FPF wrote that “any and all chemicals used in FCMs, or present in finished food contact articles as non-intentionally added substances (NIAS) or incidental contaminants (in recycled materials; FPF reported), need to be tested for their hazard properties.” To achieve this, FPF is supportive of the Generic Approach to Risk Management that is outlined in the EU’s Chemicals Strategy for Sustainability (CSS; FPF reported). Specifically, at least 388 intentionally used chemicals in FCMs have hazard properties of most concern, as laid out in the CSS, and should therefore not be allowed for use in FCM manufacture (FPF reported).
At least 610 responses to DG Sante’s survey were received. Details of the consultation’s outcome have yet to be published.
Read more
Jane Muncke (January 11, 2023). “Revision of EU rules on food contact materials: Comments on Impact Assessment stakeholder consultation.” Food Packaging Forum (pdf)
European Commission (2023). “Revision of EU rules on food contact materials.”
