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).
- Latest update: On May 6th 2019, CHEM Trust responded to the Commission’s on-line consultation as part of their evaluation of the EU laws on chemicals in food contact materials, and also submitted a position paper as an additional contribution. We have also led the development of five key principles for future EU regulation of chemicals in food contact material. See the five key principles and the list of organisations supporting them here.
Chemicals used in FCM 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. We first highlighted this issue in July 2014, and since then we have made progress in highlighting the problems – but there is a long way to go before they will be solved.
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.
- Joint presentation “EU laws on chemicals in food contact materials: a system in dire need of reform” by Michael Warhurst of CHEM Trust, Pelle Moos of consumers organisation BEUC, Sophie Perroud of HEAL and Alice Bernard of Client Earth, given at the “DG SANTE introductory workshop to support the evaluation on Food Contact Materials (FCMs) legislation” in Brussels on 24th September 2018.
- CHEM Trust sent a letter to EU Commissioners Bienkowska, Vella, Andriukaitis and Timmermans, and co-signed (with European Environment Bureau), a second letter to Member State experts on the REACH committee, both calling for the proposed REACH Restriction on four phthalates to be extended to cover use of these phthalates in Food Contact Materials. Unfortunately the Food Contact uses were not added to the REACH Restriction; see also DG Grow’s reply to our letter to Commissioner Bienkowska.
- A presentation on “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.