On January 18, 2022, the Food Packaging Forum (FPF) submitted comments to the European Commission (EC) on a draft regulation for recycled plastics FCMs in the context of a public consultation (FPF reported). The draft regulation is intended to replace the current regulation (EC) 282/2008 on recycled plastics in food contact, which is deemed not fit-for-purpose by industry stakeholders. Notably, industry targets for recycled content in plastic food packaging cannot be reached under the current approach. But as pointed out in the FPF’s comments, increasing plastic recycling contradicts the goal of reducing the overall use of single-use plastic (food) packaging. Further, both virgin and recycled plastics contain known hazardous chemicals, along with unknown chemicals which may or may not be hazardous. Therefore, the draft regulation is in contradiction with aims of both the Farm To Fork Strategy (FPF reported) and the EU Chemicals Strategy for Sustainability (FPF reported) to reduce hazardous chemicals in FCMs.
The draft regulation solidifies the current use of single-use plastic food packaging by increasing the availability of recycled plastic content that is not properly assessed for its chemical safety, because neither “incidental contamination” (i.e. novel chemicals which occur in recycled plastics due to processing of the material) nor the decontamination efficiency of novel technologies need to be assessed before market entry according to the draft. Due to these provisions exempting proper assessment, the draft regulation fails to address the real concerns with well-documented exposure to hazardous chemicals migrating from recycled plastic food packaging. Indeed, levels of known hazardous chemicals have been found to increase in recycled plastics, and more unknown chemicals are found compared to virgin materials, as is well-documented by scientific research.
FPF is concerned that the draft regulation, if passed as such, will lead to an increase in exposure to hazardous chemicals for the entire population, including the most sensitive subgroups such as children and the chronically ill.
Read More
Jane Muncke (January 18, 2022). “New regulation for recycled plastic FCM in the EU.” Food Packaging Forum
Jane Muncke (January 18, 2022). “Feedback from: Food Packaging Forum.” European Commission
Shanda Moorghen (January 20, 2022). “NGOs criticise EU plans to use novel technologies to recycle plastic into FCMs.” Chemical Watch
European Commission (March 27, 2008). “Commission Regulation (EC) No 282/2008 on recycled plastic materials and articles intended to come into contact with foods.”
