The Directorate General for Health and Food Safety (DG SANTE) of the European Commission is working on a specific regulation for printed food contact materials. Its intention is to have it by the end of 2018, but it may not be possible because it is a complex issue.
Initially, the work was started with a traditional approach similar to that of the EU Regulation 10/2011 on plastic materials and articles, based on a positive list system, but this approach faces certain points difficult to solve. One of the most important issues is the vast number of substances to be considered, which would require decades of work by the European Food Safety Authority to conclude its evaluation. Other points to be solved are the difficulty for the transmission of information along supply chains due to their complexity, frequently small food companies’ operators are the ones who have to demonstrate the compliance, the wide range of combinations to be considered (substrates, colour combination, printing techniques, etc.), the absence of guidelines for verifying the compliance and the need to ensure transparent risk assessments.
All this has lead the European Commission’s work group to propose an alternative approach based on designated bodies (consultancies or commercial laboratories accredited by Member States of the EU, which would be independent of food-contact company operators). These organisms would carry out a certification work to ensure the compliance at each stage of the manufacturing process of the food-contact printed materials. They could conduct the works in order to demonstrate compliance themselves or only to certify compliance by evaluating the work that the applicant presents.
The Commission would provide the basic rules that lead the work of the accredited agencies by means of legislation, standards, guidelines and internal rules.
There would also be a centralized database in which would be stored the dossiers of evaluations. This database would be accessible to the competent authorities, EFSA and the designated bodies to perform the evaluations, but only partially accessible to food or food-contact materials’ companies operators. This would facilitate the information exchange between the different stages of the supply chain.
Up to now, the approach to be finally adopted has not been decided yet. The Commission is disseminating this second approach to make it known and to gather opinions about it.