The 2016 “Plastics & Paper in contact with foodstuffs” Smithers Pira conference took place on December 7-9, 2016 in Brussels, Belgium. The conference presented newest developments from the food contact plastics (FPF reported) and paper fields, also covering select non-harmonized food contact materials (FCMs) such as printing inks and adhesives. An overview of regulatory updates in the EU and the U.S. was also given.

The session on regulatory updates was opened by the talk by Bastiaan Schupp, Legislative Officer FCM, DG SANTE, European Commission (EC) (FPF reported). Following, Caroline de Praeter, Food Safety Expert at the Federal Agency for the safety of the food chain (FAVV), Belgium provided an overview of enforcement work carried out by the Belgian authority. FAVV requires a Declaration of Compliance for all FCMs, including the non-harmonized FCMs. The latest piece of Belgian legislation on FCM was the Royal Decree on coatings published on September 25, 2016 (FPF reported). Belgium also has specific provisions for tin, paper and cardboard, glass, and ceramics.

Joan Sylvain Baughan, Partner at Keller and Heckman LLP, presented updates from the U.S. on FCMs. Of particular interest is the increased scrutiny of infant exposure, which must be specifically addressed in any food contact notification (FCN) sent to the U.S. Food and Drug Administration (FDA) in order to avoid a restriction. On December 9, 2016 a draft guidance for industry on preparing FCNs for food contact substances in contact with infant formula and/or human milk was published. Another issue she mentioned is the need for an environmental assessment as part of an FCN, and the recently introduced requirement to address greenhouse gas emissions.

Heng Li, Associate at Mayer Brown, provided an overview of pre-market and post-market management of food contact materials (FCMs) in China. She discussed the newly published Chinese FCM regulations (FCM reported) and explained that the legal framework applicable to FCMs in China is based on two regimes, the food safety regime and the product quality regime, with different authorities responsible under both regimes. Chemical safety of FCMs is mostly covered by the food safety regime. With regard to the post-market management of food products, Ms Li emphasized the importance of ensuring a globally harmonized approach to food and FCM safety, drawing attention to a “spill-over” effect where international compliance issues result in product recalls inside China.

Concluding the day on regulatory issues, Robert Broughton, Product Safety Manager at Amcor, presented his company’s perspective of global trading of FCMs, highlighting the need to maintain efficient communication channels, both locally and globally, and emphasizing that the work toward ensuring product safety and compliance with all regulations is of paramount importance for “protecting both your customers and your reputation.”

Read more

Smithers Pira (2016). “About Plastics & Paper in contact with foodstuffs.

FDA (December 9, 2016). “Preparation of Food Contact Notifications for food contact substances in contact with infant formula and/or human milk; draft guidance for industry; availability.