The European Commission recently published a ‘road map’ proposing options for increasing controls on the use of hormone disrupting chemical bisphenol A (BPA) in food contact materials.
CHEM Trust has been concerned about the health and environmental impacts of BPA for many years, and in our view, it should be phased out of all food contact applications.
However, as we point out in our response to this consultation, we are also concerned that the European Commission’s view of the feasibility of different options has been unduly influenced by a hitherto industry-only consultation process.
The key points we make in our response include:
- DG Sante, the Health Directorate of the European Commission, seems to have extensively consulted industry about this road map, but hasn’t consulted those representing the public interest. This is an unbalanced approach, and DG Sante must open up its processes. DG Sante should, in addition, make available all the information which industry has submitted about the costs of finding an alternative to using BPA in packaging.
- In CHEM Trust’s view the best option is number 5, i.e. a EU wide ban on BPA in all food contact materials. If DG Sante instead selects an approach based on migration limits then this must cover all food packaging materials, including plastics, coatings, varnishes, paper and board (option 4). The fact that less is known about BPA levels in paper and card is not a rationale for inaction, this is rather an indication of an ineffective regulatory system for these materials. We have been highlighting the general inadequacy of EU regulations on chemicals in food contact packaging, and the European Parliament has just started an inquiry into the issue.
- DG Sante should also consider the risks posed by BPA alternatives (e.g. bisphenol S and F), and rapidly put in place control measures for these substances.
Gwynne Lyons, Policy Director of CHEM Trust, said:
“Bisphenol A is a known endocrine disrupting chemical, which researchers have found to be active at low doses. It should be removed from all food contact applications as fast as possible.
CHEM Trust is disappointed that DG Sante seem to put so much emphasis on un-transparent pre-consultations with industry representatives, rather than on the public interest. This is not how a Directorate General for Health should be behaving.”
Media coverage after publication of the Road Map
After the publication of the Road Map, CHEM Trust’s Gwynne Lyons was quoted by Chemical Watch:
ChemTrust said the Commission should “wake up” and recognise the need for a consolidated approach to getting endocrine disrupting chemicals (EDCs) out of all food packaging materials, not just plastics.
“DG Sante seems to be hand in glove with industry as its main concerns appear to be about what is easily achievable by industry rather than protection of health,” said ChemTrust director, Gwynne Lyons.
NGOs are also concerned that they might not be consulted about the proposal, Ms Lyons said.
She was also quoted by Food Quality News:
“With all the uncertainties that were highlighted by EFSA in their risk assessment, CHEM Trust considers that peoples’ exposure to BPA should to be eliminated where possible. All types of food contact materials need to be regulated on an EU wide basis to ensure citizens across the EU are protected.”
And by ENDS Europe:
Gwynne Lyons of NGO ChemTrust said the policy roadmap “clearly shows that the food packaging industry is out of control”, with fragmented EU regulation that does not adequately protect consumers.
Update, 27th January 2016
- A European Commission DG Santé (Health) official, speaking at the European Parliament hearing on chemicals in food contact materials on 26th January, disclosed that they are already working on a measure based on ‘option 3’. This would bring in new controls on BPA in coatings (e.g. food can linings), but not on BPA in paper and card packaging. ENDS Europe have reported the story.
- CHEM Trust also launched our new briefing chemicals in food contact materials at this hearing.
Update, 19th July 2016
- In April 2016 the European Commission published a draft proposal which would apply a migration limit of 0.05mg of BPA per kg of food (mg/kg) to plastic materials and articles and varnishes and coatings found in canned foods (i.e. it doesn’t cover paper and board). This proposal is expected to be published in the Official Journal in September 2016, and apply from March 2017.