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Interview with Keller and Heckman



Ahead of the upcoming Food Contact Asia 2020 conference, we caught up with David J. Ettinger, Managing Partner at Keller and Heckman. He gave us a sneak peek of what we can expect from his presentation on day one, taking place during our 'Considerations of Food Contact Compliance' session.



Current Industry Focus:

Q. As consumers/end users continually push for safer solutions, what do you think is the biggest concern regarding food contact materials/packaging?
We always emphasize that FCMs must be compliant and safe – they must comply with the various regulations and standards, and the production process must ensure compliance with GMP requirements. Additionally, companies need to pay close attention to changes and developments that impact the materials/packaging industry. Industry needs to ensure the FCMs conform to the direction of industrial policies and plan ahead as to what products are encouraged, which may be restricted or even phased out.  For example, the Chinese government recently announced that, from January 1, 2021, the use of non-degradable plastic bags as well as disposable plastic tableware in the catering industry, etc., will be prohibited.  Thus, in addition to safety and compliance matters, companies need to take into account governmental actions that could impact the industry in a more general and broad way.

Q. What are some of the biggest opportunities gaining attention within the food contact field? 
As far as China is concerned, the regulatory framework for FCMs has been improved, becoming more clear and easier to navigate.  This facilitates the assessment of product compliance by FCM companies as they have a clearer sense of how the regulations may impact their business strategies.  In addition, through the declaration of compliance (DoC) model, there is an effective traceability system that may help reduce compliance risks along the supply chain.  

Future Focus:

Q. What industry topics are getting the most attention at this time? How are these factors influencing the future of food contact packaging/materials?
Many companies are interested in the regulatory requirements for the use of recycled materials in FCMs, the use of composite materials, and the application of new materials and new processes.  These interests will hopefully result in the government continuing to promulgate new regulations and standards or revise existing ones, while at the same time, require companies to conduct closer compliance review, particularly when there is no clear regulation or guidance, including petition for new substances when necessary.

Q. Which countries can we expect future changes from in terms of their food contact regulations?
China has been working diligently to improve the FCM regulatory system and is planning to introduce more regulations and national standards.  At the same time, China also is working on revising existing standards.  Industry must continue to pay close attention in this respect.  Notably, Japan’s new Positive List system came into effect just a few months ago.  The PL system currently only applies to synthetic resins, but will be extended to other FCMs such as paper in the future.  Since the current PL system has recently been implemented, there remain many areas that need to be clarified.  Thus, industry also should pay close attention to the development of the FCM system in Japan.

Q. What opportunities are there for harmonization of food contact regulations in the Asia Pacific region?
It seems unlikely, particularly because the consumption habits, industry development levels, current regulatory system, etc., are very different among the countries in the Asia Pacific region. We do not believe a harmonization of FCM regulations in this region will be coming any time soon.

Conference Related:

Q. Your presentation at this year’s Food Contact Asia will cover Declaration of Compliance, Why is it important for others in your industry to hear this message? What are some of the key take-aways?
DoC or similar customer assurance statements are becoming mandatory in more and more countries.  The DoC concept is an effective traceability tool that companies can rely on to obtain sufficient information for safety assessment and avoid possible compliance risks brought by upstream companies.  However, DoC requirements in many countries are very general in nature, without sufficient guidance for industry to follow.  Companies need to know what kind of DoC  meets the regulatory requirements, not only to help them comply with the issuance of their own DoC, but to help determine whether the DoC they receive from upstream companies meet the requirements.  Our presentation touches on the DoC requirements in the EU and the US, but mainly focuses on the particulars to be included in a China DoC.

Q. Which presentations (what session topic) are you most looking forward to hearing about at Food Contact Asia?  
We are interested to hear about the FCM regulations in other Asian jurisdictions, like Japan and Korea. We also look forward to hearing about the FCMs case studies for different applications.