Current Industry Focus:
Q. What are the current food contact priorities for you and your business?
We caught up with experts from PlasticsEurope
, who will be presenting at next month's Food Contact Asia 2021
Our main priority is and will be that our food contact materials stay in compliance to the constantly changing global regulatory landscape.
For information in Europe, the European Commission has published last year September an amendment (Regulation (EU) No. 2020/1245) with far reaching consequences for plastic food contact materials and articles. This amendments contains a requirement for the migration of substances for which genotoxicity cannot be ruled out in the intermediate food contact material and could give rise to a migration from the final material in an amount exceeding 0,00015 mg/kg (0,15 ppb) food or food simulant. For which we have deliberated an interpretation paper:
End of this year the European Commission will publish via an amendment a new format for an EU wide declaration of compliance (food contact declaration).
Q. What do you consider to be one of the biggest food contact challenges the packaging industry is facing, especially in APAC region?
A further harmonization of the Chinese GB standard for food contact to the EU food contact requirements, such as the introduction of a requirement for the risk assessments of non-intentionally added substances (NIAS) and not listed substances (NLS).
On the other hand, it will give packaging industry the possibility to market their food contact materials and articles more globally, since it will remove any compliance barriers.
Q. What are the most important changes in the food contact landscape you are seeing?
The requirement that also (mechanically) recycled plastic materials can or have to be used in food contact materials and articles.
Q. What regulatory changes do you anticipate seeing in the future?
The European Commission has already indicated that recycled plastic materials for food contact applications also have to comply with the food contact requirements, as virgin materials.
However, in contrast to virgin plastic materials, mechanically recycled plastic materials have an unknown and not guaranteed chemical composition. This means that all intentionally added substances (IAS), NIAS and NLS of every used batch of mechanically recycled plastic materials has to be assessed to ensure that they are safe. In addition, only closed loop recycled plastic materials can be used for food contact applications and therefore will required a separate waste collection system for food contact materials and articles. This means a huge burden for packaging industry.
Plastic Europe is anticipating on the use of mechanically recycled plastic materials in food contact materials and will participate in an EU project, called "RISAIKURUn, on the assessment of NIAS in recycled plastic materials" and which will be facilitated by different stakeholders under the lead of the Spanish plastic technology institute AIMPLAST, where we will pass on our expertise and experience on the risk assessment of NIAS and NLS in plastic materials, as well as our expertise of the composition of plastic materials.
Q. How can you ensure you stay compliant with the latest food contact regulations and best practice?
By first knowing in-depth the different food contact regulations and its requirements and secondly by applying a sound compliance and best practices policy.
Q. What opportunities are there for harmonization of food contact regulations in the Asia Pacific region?
One of the opportunities of a harmonized food contact regulation in e.g. the Asia Pacific region will be, that food contact materials and articles produced or imported in that region can be easily marketed without any regulatory obstacles. Moreover, it also will lead to less compliance burden by the packaging industry.
Q. Could you please give us a quick sneak peek of what we can expect to hear during your presentation? Why is it important for others in your industry to hear this message?
The Chinese GB standard 4806.1-2016 contains in imitation to the European food contact regulation, a paragraph (par 2.13) on non-intentionally added substances (NIAS) as well as a requirement that the final food contact material or article may not release substances that could endanger human health.
However, the GB standard 4806.1-2016 does not contain such as the European food contact regulation, a paragraph that NIAS and also not listed substances (NLS) to a risk assessment according to internally recognized principles, to finally indicate that these substances do not pose any risk for the consumer, such as required in paragraph 3 of this GB standard.
During our presentation, we would like to engage you on our experiences of the risk assessments of plastic food contact materials and the tools and guidance that are developed:
Q. What are you most looking forward to at Food Contact Asia?
The responds on our paper and the questions of the participants of our experiences with risk assessments.