On September 2, 2019, the European Commission (EC) published the factual summary report for the public consultation on the evaluation of food contact materials (FCM) regulation in the EU (FPF reported). The consultation was held in spring 2019 (FPF reported).  There were 503 responses received in total, 44% of which were from citizens, 41% from businesses, 7% from public authorities, and the rest from other stakeholders, including non-governmental organizations (NGOs). The citizen responses show “a high level of trust” in FCM safety in the EU, the report summarizes, with only 4% of respondents indicating the lack thereof. However, “despite high trust in the safety of FCMs on the EU market, most EU citizens responding (66%) do not know which authority is responsible for addressing complaints in cases of concerns about the safety of FCMs.” Among the experts responding to the consultation (56% of all respondents), 72% were representing businesses, 13% public authorities, 7% NGOs, and 8% “other experts.” Overall, “experts consider the definitions provided by Regulation 1935/2004 as sufficient and clear.” However, “majority of NGOs (89%) . . . perceived the current definitions provided by the legislation as not sufficient,” the report summarizes (FPF reported). Further, “majority of businesses (71%) believe that in general it is not possible to demonstrate compliance with the general safety requirements set out in Art. 3 of Regulation 1935/2004 without having access to significant resources.” In addition, “a large majority of respondents (94% of the total number of respondents, across all categories) indicated that more harmonization at EU level is desirable, compared to individual Member State legislation.” 

The EC also published the factual summary report for the SME Panel survey which “aimed to collect the views of micro, small and medium enterprises (SMEs)” on the EU FCM legislation, with a particular focus on gathering “views and evidence from small companies operating in the Food Contact Material supply chain on the functioning of the FCM legislation and about how the legislation affects businesses in the EU.” The survey respondents covered “701 SMEs from 21 Member States,” the majority of them representing either processors or manufacturers of food products (42%), or manufacturers of final articles or converters (19%). The responder companies declared to be active in plastics (67%), paper and board (64%), glass (34%), and other FCMs. The report summarizes that “48% of SMEs indicated that they did not experience any difficulties in complying with the FCM legislation or in selling FCMs on the EU market in the past,” while “21% of respondents reported to have encounter[ed] difficulties to comply with the regulation.” With regard to “the administrative costs stemming from the FCM regulation for SME businesses,” 79% of respondents “indicated that FCM regulation represent[s] less than 2% of their total administrative costs,” thus the overall burden “appears to be rather small (none or less than 1%) across all SME types, the report concludes. However, only “39% respondents believe that the needs of their business are sufficiently addressed . . .  by the current FCM Regulation.” Similarly to the public consultation, “a large majority” of SME survey respondents “indicated that harmonization at EU level would ensure a better functioning of the EU internal market and could help to achieve higher and more uniform safety standards across MS.” 

A stakeholder workshop to further discuss the presented findings will be held on September 9, 2019, in Brussels, Belgium (FPF reported). 

Read more 

EC (September 2019). “Factual Summary report. Public Consultation for the Study supporting the Evaluation of Food Contact Materials (FCM) legislation – (Regulation (EC) No 1935/2004).” (pdf) 

EC (September 2019). “Factual Summary report. SME Panels for the Study supporting the Evaluation of Food Contact Materials (FCM) legislation – (Regulation (EC) No 1935/2004). (pdf)