On July 3, 2015 the peer-reviewed scientific journal Food Control published a study entitled “Compliance work for polyolefins in food contact: Results of an official control campaign”. The authors are scientists working for various Swiss enforcement authorities, including the Official Food Control Authority of the Canton of Zurich.
In their article, Gregor McCombie and colleagues report results from an enforcement campaign focusing on the Declaration of Compliance (DoC) and its related Supporting Documentation (SD). They asked Swiss converters of polyolefin granulates to provide DoC and follow the chain of business operators backwards, asking the manufacturers of the raw polyethylene (PE) and polypropylene (PP) granulates to send in their DoC and particularly the SD. In the SD, the safety of not specifically regulated components that potentally migrate needs to be demonstrated, as specified by EU Regulations.
In total, nine resin manufacturers were reached. All sent a DoC, but none provided a SD within six months after receiving the legally binding request. Following media reporting on the campaign (FPF reported) four manufacturers provided some additional SD. The focus was on the raw granulate producers, since the completeness of their compliance work is the basis for their customer’s ability to meet their obligations regarding compliance work.
McCombie and colleagues also analyzed the PE and PP resins for the presence of potential migrants. In their article, they point out that legal compliance needs to be performed for any potentially migrating substance present in food contact materials (FCMs), according to Article 3 of the European FCM Framework Regulation (EC 1935/2004). They write that “every substance introduced, their reaction products formed in the FCM or in the food as well as the impurities must be safe at the level they may migrate”. According to them “most material migrating from polyolefins into food consists of oligomeric substances and related reaction products”. Since the oligomers of polyolefins are structurally related to the mineral oil saturated hydrocarbons (MOSH), they are of concern because of potential accumulation in human tissues and related health effects.
They also detected several dozens of other substances possibly migrating at relevant levels, including the endocrine disrupting chemical nonylphenol; for some of these compounds no information about identity and safety was obtained. However, the authors infer that the complexity is not excessive, and that the corresponding compliance work is feasible. Notably, they also considered migration below the EU’s conventional detection limit of 10 ppb due to toxicological reasons.
Apparently, the concept of systematic compliance work and its documentation has not been implemented by FCM manufacturers, according to McCombie and colleagues, even though it has been legally required for more than 10 years. They conclude that moving forward, “either reality is accepted and the current concept of strictly protecting the consumers from toxic migrants [is] abandoned, or enforcement needs to be given effective tools to implement the existing legislation.”
McCombie, G. et al. (2015). “Compliance work for polyolefins in food contact: Results of an official control campaign.” Food Control 59:793-800.