Food packaging, factory equipment, food utensils – almost everything we eat has been in contact with one or more of these items, which are classified in EU law as ‘Food Contact Materials’ (FCMs).
- Update, May 2018: For an up-to-date summary of the problems with chemicals in food contact materials, and the failing EU regulation system, see this new presentation at a Chemical Watch conference: “EU regulation of chemicals in Food Contact Materials: Outdated, ineffective – and full of holes“. Chemical Watch’s coverage of the conference, repeats part of our title: “EU regulation of FCMs ‘outdated and full of holes'”.
Chemicals used in these materials are regulated at EU level by a “Framework Regulation” which requires that FCMs “do not transfer their constituents to food in quantities which could endanger human health”.
However, beyond this general safety requirement, some materials like plastics are regulated more precisely by EU rules, others – such as paper and card, inks, coatings and adhesives – are not covered by a specific EU regulation.
In CHEM Trust’s view, the lack of EU harmonised rules on many food contact materials and other holes in the system – including the continued use of substances of very high concern in food packaging – means that public health is not properly protected. This lack of harmonisation can also lead to disruption of the internal market.
CHEM Trust’s contributions on this issue have included:
- Highlighting the lack of action by EFSA and the European Commission’s DG Health in considering the safety risks of BPA replacements such as BPS.
- A briefing, “Chemicals in food contact materials: A gap in the internal market, a failure in public protection”, which outlines key problems and recommendations – first published in January 2016.
- Our response to the EU Commission’s Draft Roadmap on “Evaluation of Food Contact Materials (FCM)”, 21st December 2017.
- Our most recent presentation on the subject is “EU regulation of chemicals in Food Contact Materials: Outdated, ineffective – and full of holes” by Michael Warhurst at Chemical Watch’s “Food Contact Regulations Europe 2018” conference on 7th May 2018.
- Other presentations, including “Chemicals in food contact materials (FCM) – it’s a mess” presentation at the Food Packaging Forum webinar on substances of very high concern in FCM in March 2017, and a talk on “Addressing chemicals of concern in food contact materials – including those made from recycled materials” at the Food Packaging Forum Conference in 2016.
- CHEM Trust organised a workshop in Brussels to examine one important aspect – the overlap and gaps between the main EU chemicals regulation REACH and the food contact materials laws. Details and notes can be found in this blog.
- Comments to the European Commission consultation on its road map on Bisphenol A in food contact materials, and to the European Food Safety Authority on risk assessment of chemicals in food contact materials, both in 2015.
- Responding to a consultation on an EU Commission Draft Regulation on “Bisphenol A in varnishes and coatings and plastics intended to come into contact with food” in September 2017.
- Many blogs, for example on the EU Commission’s recent plans to evaluate the laws on FCM and to develop a regulation for printed food contact materials and on the secrecy of the EU’s regulatory and policy processes in this area.
You can read all our blogs on chemicals in food packaging and other food contact materials here.
More information on chemicals in food contact materials is available from the Food Packaging Forum.