Food Contact Materials | Monthly bulletin | November 2019
Regulatory news - Commercial news
Upcoming dates of application: Regulation (EU) 2019/37 for plastic materials
As a reminder, below you will a summary of the legislation that will start applying within the next six months:
Manufacturers and importers should carefully consider these coming dates of application and confirm that their products comply with:
- Commission Regulation (EU) 10/2011 - Plastic materials and articles intended to come into contact with food
Plastic materials and articles complying with Regulation (EU) No 10/2011 as applicable before the entry into force of Regulation (EU) 2019/37 of 10 January 2019 may be placed on the market until 31 January 2020 and may remain on the market until exhaustion of stocks.
It will start applying on 31st January 2020.
Below a summary table with recent regulation proposal notified to European Commission (Non-exhaustive):
|
Notification number |
Countries |
Title |
|
UK |
The Deposit and Return Scheme for Scotland Regulations 2020
The aim is to promote and secure an increase in recycling of materials. The main points, between others, are:
|
Potential health risks in colourful printed paper
On 26th September 2019, the German Federal Institute for Risk Assessment (BfR) published the Opinion No. 037/2019 (in German) about potential health risks posed by colourfully printed paper-based food contact materials.
They measured migration of the following 4 chemical substances related to azo dyes in paper food contact materials:
|
Chemical name |
CAS number |
|
3-hydroxy-2-naphthanilide (naphthol AS) |
92-77-3 |
|
2′,4′-dimethylacetoacetanilide (NAAX) |
97-36-9 |
|
Acetamide,N-(2-chloro-4-methylphenyl) (NDPA) |
2050-43-3 |
|
3-hydroxy-2-naphthoic acid (HNS) |
92-70-6 |
BfR indicates that the toxicological data is insufficient to evaluate the safety of these substances which have been found in food. In conclusion, BfR recommends that any materials that release these substances or their precursors should not be used in contact with food.
New recycling legislation
Recently, the U.S. State of California approved the following bills related to recycling legislation:
AB-1583 The California Recycling Market Development Act: Existing law requires the Department of Resources Recycling and Recovery to develop a comprehensive market development plan that will stimulate demand of recycled materials. This bill would delete the triangle symbol “chasing arrows” that is currently indicated in the packaging.
AB-827 Solid waste: commercial and organic waste: recycling bins: It would require a commercial business to provide customers with a recycling bin or container for their waste. Full-service restaurants would be exempted. It would also require the Department of Resources Recycling and Recovery to develop model signage that commercial and organic waste generators may utilize to mark the recycling bins provided to customers.
New substances added to FDA inventory of Effective Food Contact Substances
The following substances have been recently added to the Inventory of Effective Food Contact Substances (FCS) Notifications of the U.S. Food and Drug Administration (FDA).
|
FCN number |
Substances |
Date |
|
A mixture of 1-decene, polymer with sulfur dioxide (CAS Reg. No. 33990-98-6); 1,3-propanediamine, N1-(9Z)-9-octadecen-1-yl-, polymer with 2-(chloromethyl)oxirane (CAS Reg. No. 1010121-89-7); and dodecylbenzenesulfonic acid (CAS Reg. No. 27176-87-0). REPLACES FCN 1819 |
Sep 14, 2019 |
|
|
An aqueous mixture of peroxyacetic acid (CAS Reg. No. 79-21-0), hydrogen peroxide (CAS Reg. No. 7722-84-1), acetic acid (CAS Reg. No. 64-19-7), sulfuric acid (CAS Reg. No. 7664-93-9), and 1-hydroxyethylidine-1,1-diphosphonic acid (HEDP) (CAS Reg. No. 2809-21-4). REPLACES FCN 1850 |
Sep 11, 2019 |
New requirements for food packaging
Recently, the Indonesia’s National Agency of Drug and Food Control (BPOM) published new regulations for food packaging.
The aim is to provide packaging which does not endanger human health. It covers new and recycled materials such as plastics, inks and dyes, paper and paperboard, resins and polymer coatings, metals, ceramics, and glass.
The annexes contained in the legislation are:
- (i) Prohibited substances
- (ii) Permitted substances with a specific migration limit
- (iii) FCMs and their total migration limits
- (iv) Specifications for materials used as packaging by food and beverage type
It came into force on 29th July 2019 and all packaging must comply with these new regulations by 29th July 2020.
Please, click here for getting the BPOM’s publication.
Regulatory proposals notified to WTO
Below a summary table with some recent notifications to World Trade Organization (non-exhaustive):
|
Notification number / Link |
Country |
Title |
|
Japan |
Establishment of the quantity specified by the Minister of Health, Labour and Welfare as the quantity that is unlikely harm to human health |
|
|
Japan |
Partial amendment to the Specifications and Standards for Foods, Food Additives, Etc. (Ministry of Health and Welfare Notification No. 370 of 1959) and the Ministerial Ordinance on Milk and Milk Products Concerning Compositional Standards, Etc. (Order of the Ministry of Health and Welfare No. 52 of 1951)
Partial revision of the specifications and standards for utensils, containers, and packaging for milk and milk products |
Below you will find a monthly summary of product recalls and alerts in Europe (Source “RASFF”) and in the US (Source “CPSC”)
Europe
RASFF (European Commission Rapid Alert System for Food and Feed - Alerts reported by EU national authorities)
The following 13 alerts regarding Food Contact Materials. have been reported, from 21st September to 20th October of 2019.
|
Product |
Substance / Hazard |
|
|
Polyamide sausage |
Too high level of overall migration (18.7 mg/dm²) |
|
|
Plastic bottles |
Deterioration of organoleptic characteristics (smell and taste) of water |
|
|
Ceramic knives |
Sharp fragments |
|
|
Barbeque grid |
Migration of zinc (660 mg/kg - ppm) |
|
|
Grill and dripping plate |
Migration of nickel (0.3 mg/kg - ppm) |
|
|
Dessert steel forks |
Migration of chromium (0.11; 0.47; 0.59 mg/l) |
|
|
Melamine tableware and bamboo plates |
Migration of formaldehyde (24.1 mg/kg - ppm) |
|
|
Oven grill and dripping pan |
Migration of nickel (0.5 mg/kg - ppm) |
|
|
Oven grill and dripping pan |
Migration of nickel (0.5 mg/kg - ppm) |
|
|
Electric fryer grills |
Migration of iron (98.3 mg/kg - ppm) and too high level of overall migration (69 mg/dm²) |
|
|
Bamboo mug |
Migration of formaldehyde (up to 207.8 mg/kg - ppm) |
|
|
Nylon kitchen utensils |
Migration of primary aromatic amines (aniline: 943; 4,4'MDA: 40000 µg/kg - ppb) |
|
|
Toaster |
Unfit for use as food contact material (steel AISI 201) |
|
From on 21st September to 20th October 2019, CPSC (Consumer Product Safety Commission) has published the following recalls: 0 recalls regarding Food Contact Materials.
Webinar "NIAS the huge challenge for the food industry" in English
NIAS: Non-intentionally added substances
Within this webinar you will learn about definitions and legal aspects of NIAS as well as analytical approaches and challenges plus risk assessment tools.
