The safety of food contact packaging

For some years now, packaging manufacturers and the food industry have become aware of the importance of guaranteeing the safety of food contact materials. Moreover, regulations set that food contact materials and articles must comply a series of general guidelines for materials maximum inertness, absence of toxicity and so that they don’t change food’s smell and taste. These requisites for food contact materials are established in the general legislation, which is the Regulation (EC) nº 1935/2004, also known as framework legislation. As an extension of this framework document, and as specified in the Regulation (EC) nº 2023/2006, materials must be manufactured based on Good Manufacturing Practice.

This framework legislation only establishes general requirements; it does not set guidelines or criteria to guarantee product suitability for coming into contact with food. Additional regulations are required because each material needs specific measures. At the moment, there is specific European legislation for:

• Plastic materials: Regulation (EC) nº 10/2011
• Regenerated cellulose: Directive 2007/42/EC
• Active and intelligent materials: Regulation (EC) nº 450/2009
• Recycled plastics: Regulation (EC) nº 282/2008
• Elastomers and rubbers: Directive 93/11/EC
• Ceramics: Directive 84/500/EC and Modification 2005/31/EC.

The problem is that, almost 10 years after the publication of the framework legislation, some materials are still being used with no food safety specific regulations, putting our health at risk. In many cases there are national regulations (which are only mandatory in those countries) or non-legally binding guidelines published by different organizations which provide guidance regarding methods to analyze compliance with legislation. Nevertheless:

• Any Member State has legislation for every material.
• In most national legislation cases, there are no specific requisites.
• In many occasions, substances fixed limits vary between countries. This impedes free movement of products between countries inside the UE.

In 2012, the European Commission published “Road Map”, which analyzes the potential solutions for this problem. The Member States would consult along with EFSA (European Food Safety Authority) and companies from the food contact materials industry, food companies, importers, national entities and private institutes. The aim of these consultations is to evaluate the best way to modify the current situation in order to ultimately achieve control increase and safety of all food contact materials.