On March 3rd a group of 33 scientists from around the world published a peer reviewed Consensus Statement expressing deep concern about the current use of harmful chemicals in food packaging and other Food Contact Materials (FCM).
The scientists cover several fields of expertise, including developmental biology, endocrinology, epidemiology, toxicology, and environmental and public health. Their statement, which was based on more 1200 peer reviewed studies, urge decision makers to improve legislation on food contact materials and articles to ensure protection of public health.
The scientists’ Statement was followed by a Declaration of Concern and Call to Action, signed by CHEM Trust and more than 170 civil society groups from Europe, the U.S. and Asia calling on regulators to upgrade regulatory frameworks. In view of the scientists’ findings, the Declaration calls on lawmakers to:
- Ensure full disclosure and traceability of chemicals used in packaging throughout the supply chain;
- Restrict the use of hazardous chemicals in food packaging (and products), and prevent regrettable substitutions, and;
- Adopt policies that support the transition towards safe, reusable, and refillable packaging.
The Consensus Statement reveals widespread concern amongst scientists about FCMs as an exposure pathway for known hazardous substances such as bisphenols and phthalates, as well as for a plethora of toxicologically uncharacterized chemicals.
The authors have analysed existing lists of chemicals used in food contact materials issued by legislators, industry, and NGOs worldwide. They found that today almost 12,000 chemicals are potentially in use in the manufacture of food contact materials, but the harmful effects of many of these substances have not been sufficiently tested.
The scientists emphasize that thousands of chemicals in FCM lack data on their hazardous properties and also lack data on the level of human exposure, even though this is crucial for determining human health risks. The statement further explains how an unknown and presumably even higher number of so-called Non-Intentionally Added Substance (NIAS) in food contact materials may migrate into food, especially from recycled materials.
7 priorities for action
The Consensus Statement provides an overview of areas of concern and related activities that would improve the safety of food contact materials and support a circular economy.
Seven important areas in need of improvement are highlighted:
- Eliminating hazardous chemicals in food contact articles;
- Developing safer alternatives;
- Modernising risk assessment;
- Including endocrine disruption;
- Addressing mixture toxicity;
- Improving enforcement;
- Establishing multi-stakeholder dialogue to find practical solutions.
The scientists state that there is a need for revising how the safety of migrating chemicals is assessed, using current scientific understanding. At the same time different stakeholders are pushing for solutions to reduce packaging waste and end plastic pollution, but often not taking chemical safety into consideration. The scientists encourage all stakeholders to focus more on hazardous chemicals and stress that including chemical safety considerations in the development of sustainable packaging will lead to solutions that are beneficial to both human and environmental health.
New EU legislation may be underway
The timing of this very clear statement from the scientific community seems particularly relevant in the EU as the European Commission has recently conducted a (still un-published) evaluation of the existing EU legislation on food contact materials and is in the process of deciding on the next steps.
In the last few weeks there has been some indications that the Commission will be taking steps to improve the current legislation on FCMs. These include a response from the new Commissioner for Health and Food Safety to a letter from CHEM Trust, which acknowledged that there is need for improvement to the legislation.
At a recent Chemicals Watch conference in February 2020, Legal Officer Bastiaan Schupp, DG Sante, told participants that the Commission is planning to begin an impact assessment and consultation of policy options in 2020 before possibly proposing new harmonised EU legislation on FCM.
Moreover, under the overarching European Green Deal, the new Commission, has committed to deliver a “Zero pollution ambition for a toxic free environment” and “a fair, healthy and environmentally-friendly food system”. Reforming the regulatory framework for FCM – in line with the scientists’ advice – may well be seen as an essential element in achieving these goals, and also as a prerequisite for the overall success of the Green Deals’ most important chemicals related sub-strategies: The Sustainable Chemicals Strategy, the Farm-to-Fork Strategy, and the Circular Economy Action Plan, which are all expected in 2020.
Sidsel Dyekjaer, Science and Policy Consultant at CHEM Trust said:
European Consumers should always be able to buy safe food in safe packaging. The lack of political will to take control of harmful chemicals in FCM has been accepted for too long. The scientists’ Consensus Statement confirms the increasing urgency, and the clear need to make a full reform of the regulatory framework for FCM a top priority under the European Green Deal.
- See our page on chemicals in food contact materials for more information about this issue.