Food Contact Materials | Monthly bulletin | October 2019
Regulatory news - Commercial news
New amendments for stainless steels and resins
On 16th August 2019, the Decree Nº 72 of May 9 2019 came into effect. This amendment applies to Section 6 Stainless steel of Annex II of the Decree of the Ministry of Health of 21 March 1973 Hygiene regulation for packaging, containers and utensils intended to come into contact with foodstuffs or substances for personal use.
The main changes are:
- The following eight types of stainless steel are added to part A: (List of stainless steels that can be used in contact with food):
|
UNI EN 10088-1 |
AISI/ASTM |
UNS |
|
|
Code |
Alphanumeric code |
||
|
1.4598 (*) |
|
AISI |
316LK |
|
1.4611 |
X2CrTi 21 |
|
|
|
1.4613 |
X2CrTi 24 |
|
|
|
1.4618 |
X9CrMnNiCu17-8-5-2 |
|
|
|
1.4547 |
X1CrNiMoCuN20-18-7 |
|
S31254 |
|
|
X2CrNiMnMoCuN21-3-1-1 |
|
S82031 |
|
|
X2CrMnNiMoCuN20-3-1-1 |
|
S82012 |
|
|
X2CrNiMoN 21-9-1 |
ASTM |
S31655 |
|
(*)Provided that the objects manufactured with this steel are intended exclusively for the manufacture of parts of valve components in contact with water |
|||
- Update of the table of composition range of elements of part B:
|
Type |
C% |
Si% |
Mn% |
P% |
S% |
N% |
Cr% |
Cu% |
Mo% |
Nb% |
Ni% |
Ti% |
Other Elements% |
|
a |
0.05 max |
1.0 max |
2.0 max |
0.045 max |
0.030 max |
0.08–0.20 |
22.0–25.0 |
- |
2.5–3.5 |
- |
4.5–6.5 |
- |
- |
|
b |
0.08 max |
1.0 max |
3.8–7.5 |
0.045 max |
0.015 max |
0.05–0.25 |
17.0–18.0 |
1.5–3.5 |
|
- |
3.5–5.5 |
- |
- |
|
c |
0.03 max |
2.00 max |
1.00 max |
0.04 max |
0.25–0.35 |
- |
17.0–19.0 |
- |
1.50–2.50 |
- |
- |
- |
- |
|
d |
0.08 max |
1.00 max |
2.50 max |
0.04 max |
0.15–0.35 |
- |
17.5–19.5 |
- |
1.50–2.50 |
- |
0.75 max |
- |
- |
|
e |
0.08 max |
1.00 max |
1.50 max |
0.04 max |
0.25–0.35 |
- |
16.0–18.0 |
- |
0.80–1.70 |
- |
0.50 max |
- |
- |
|
f |
0.010 max |
0.50 max |
0.50 max |
0.040 max |
0.030 max |
0.015 max |
13.75–15.00 |
- |
- |
0.10–0.30 # |
- |
0.05–0.20 # |
Sn 0.10–0.25 |
|
g |
0.010 max |
0.50 max |
0.50 max |
0.040 max |
0.030 max |
0.015 max |
16.00–18.00 |
0.40 max |
- |
0.10–0.25 # |
0.40 max |
0.05–0.15 # |
Sn 0.10–0.50 |
|
h |
0.020 max |
1.00 max |
1.00 max |
0.040 max |
0.006 max |
0.025 max |
19.00–21.00 |
0.30–0.60 |
- |
0.30–0.80 # |
0.60 max |
0.20 max |
- |
|
i |
0.8–0.95 |
0.35–0.5 |
0.25–0.4 |
0.4 max |
0.03 max |
- |
17–18 |
- |
1–1.25 |
- |
0.25 max |
- |
V 0.08–0.12 |
|
l |
1.85–1.95 |
0.40–0.80 |
0.20–0.50 |
0.03 max |
0.03 max |
- |
19.00–21.00 |
- |
0.80–1.20 |
- |
- |
- |
V 3.80–4.20 |
|
m |
Max 0.03 |
Max 1.00 |
Max 0.80 |
Max 0.040 |
Max 0.015 |
Max 0.030 |
20.00 24.00 |
0.30 0.80 |
Max 0.035 |
0.10 0.70 |
- |
0.10 0.70 |
V 0.03 0.50 |
Other important amendment that has been published this year related to food contact materials is the Decree Nº 30 of February 7, 2019. It modifies Annex II - List of authorized substances for the preparation of objects intended for contact with food, Section 1: Plastics of the Decree of the Ministry of Health of 21 March 1973.
The following entry is added in Annex II, Section 1, Part A: Resins:
|
Substance |
Requirement |
|
N, N, N', N'-tetrakis(2-hydroxyethyl) adipamide |
For the production of polymeric dispersions of polyolefin polymers functionalized with acrylic groups and / or anhydrides, used as coatings on metals, at a maximum use percentage of 6% with respect to the dry weight of the dispersion. For all types of food, in contact conditions of sterilization and / or pasteurization followed by prolonged storage at room temperature or below |
It was effective on 24th April of 2019.
Organic fluorinated compounds ban in paper and cardboard
On 2nd September 2019, Danish Ministry of Environment and Food announced its plan to ban per- and polyfluoroalkyl substances (PFAS) in paper and cardboard used in food contact materials. It will take effect in July 2020.
The ban includes the use of all organic fluorinated compounds in paper and cardboard food contact materials. It will be possible to continue using recycled paper and paperboard for food contact, but if there is a fluorine content in the material, then it must be separated from the food with a barrier which ensures that fluoride does not migrate into the food.
Click here for getting more information from Danish Ministry of Environment and Food’s website (in Danish)
List of standards under ProdSG updated
On 6th September 2019, in the Joint Ministerial Journal No. 35 the Federal Institute for Occupational Safety and Health announced the references to the standards and other technical specifications identified by the Committee for Product Safety (AfPS) according to the Product Safety Act – ProdSG.
For food contact products the updated standard is:
|
Code |
Title |
Replaced standard |
|
DIN ISO 8442-9 September 2018 |
Materials and articles in contact with Foodstuffs - Cutlery and Tableholloware -Part 9: Requirements for ceramic knives (ISO 8442-9: 2018); German version EN ISO 8442-9: 2018 |
- |
Recently, the German Institute for Occupational Safety and Health (BAuA) published the new Updated AfPS Guide (AfPS GS 2019:01 PAK) for testing and evaluation of PAHs (Polycyclic Aromatic hydrocarbons) under GS Mark.
The main changes compared to the current still valid AfPS GS 2014:01PAK, are the following:
- The scope of categories 1, 2a and 3a has been extended to "use by children"
- The list of PAHs has been shortened from 18 to 15 PAHs. Acenaphthylene (CAS No. 208-96-8). Acenaphthene (CAS No. 83-32-9), and fluorene (CAS No. 86-73-7) have been removed from the substance list
- The term "Gefährdungsbeurteilung (risk / hazard assessment)" has been replaced by the term" Risikobeurteilung (risk assessment)"
When the GS mark is awarded, this new version must be applied from 1 July 2020 (including current procedures completed after 1 July 2020).
Existing GS mark certificates remain valid.
Ban and restriction for single-use food ware plastics
From 1st July 2019, the Single-Use Food ware Plastics, Toxics, and Litter Reduction Ordinance (File No. 181004) took effect in the City and County of San Francisco.
It prohibits the sale and/or restricts the distribution of plastic food ware accessories and bans toxic fluorinated chemicals in compostable paper food ware.
Below a summary table with the dates, bans and restrictions:
|
|
Starting 1st July 2019 |
Starting 1st July 2020 |
|
Retailers |
Prohibition to sell single-use plastic stirrers, plastic beverage plugs, plastic cocktail sticks or plastic toothpicks |
Compostable Food ware Criteria: They must be Biodegradable Products Institute (BPI) certified Such as paper or other natural fiber to-go containers and straws, grease resistant paper, and paper plates |
|
Food & Beverage vendors: |
Straw Restriction: A single-use plastic straw may only be provided to a customer who specifically requests a plastic straw to accommodate a disability or medical need |
|
|
Plastic Accessories Ban Prohibition to provide single-use plastic stirrers, plastic beverage plugs, plastic cocktail sticks, and plastic toothpicks |
|
|
|
All Food and Beverage Accessories: It is prohibited to deliver them in a customer’s order for dine in or take away |
|
|
|
|
Compostable Food ware Criteria: They must be BPI certified Such as paper or natural fiber to-go containers and straws, grease resistant paper, and paper plates The following articles do not need to be BPI certified: Napkins, stirrers, splash sticks, cocktail sticks, toothpicks, or utensils made entirely of natural fiber like paper |
More information is available at San Francisco Department of Environment’s website: about Plastic , litter, and toxics reduction law and purchasing and usage guidelines.
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 |
|
Acrylic resin derived from styrene (CAS Reg. No. 100-42-5), ethyl acrylate (CAS Reg. No. 140-88-5), and acrylic acid (CAS Reg. No. 79-10-7) |
Aug 31, 2019 |
|
|
Polyester-polyurethane adhesive formulated from the following: 1,3-benzenecarboxylic acid (CAS Reg. No. 121-91-5); 2-ethyl-2-(hydroxymethyl)-1,3-propanediol (CAS Reg. No. 77-99-6); hexanedioic acid (CAS Reg. No. 124-04-9); 1,2-propanediol (CAS Reg. No. 57-55-6); diphenylmethane 4,4'-diisocyanate (CAS Reg. No. 101-68-8); bis(isocyanatophenyl) methane (CAS Reg. No. 26447-40-5); castor oil (CAS Reg. No. 8001-79-4); 1-propanamine, 3-(trimethoxysilyl)-N-[3-(trimethoxysilyl)propyl]- (CAS Reg. No. 82985-35-1); poly[oxy(methyl-1,2-ethanediyl)], α-hydro-ω-hydroxy- (CAS Reg. No. 25322-69-4); ethanol, 2,2'-[1,2-ethanediylbis(oxy)]bis- (CAS Reg. No.112-27-6); poly[oxy(methyl-1,2-ethanediyl)], α,α',α''-1,2,3-propanetriyltris[ω-hydroxy- (CAS Reg. No. 25791-96-2) |
Aug 21, 2019 |
|
|
Cellulose acetate (CAS Reg. No. 9004-35-7), and optionally modified with propionate to form cellulose acetate propanoate (CAS Reg. No. 9004-39-1) resulting in up to 49 weight-percent propionate esters |
Jul 11, 2019 |
|
|
2-Propenoic acid, 2-methyl-, polymer with butyl 2-propenoate, ethenylbenzene, 2-ethylhexyl 2-propenoate, methyl 2-methyl-2-propenoate and 2-methylpropyl 2-methyl-2-propenoate (CAS Reg. No. 1515850-94-8) |
Aug 9, 2019 |
|
|
2-Propenoic acid, 2-methyl-, methyl ester, polymer with butyl 2-propenoate, ethenylbenzene, 2-ethylhexyl 2-propenoate, 2-methylpropyl 2-methyl-2-propenoate and 2-propenoic acid (CAS Reg. No. 103235-87-6 |
Aug 9, 2019 |
|
|
2-Bromo-2-nitro-1,3-propanediol (CAS Reg. No. 52-51-7) |
Aug 1, 2019 |
|
|
Fluorocarbon cured elastomer produced by copolymerizing tetrafluoroethylene (CAS Reg. No. 116-14-3) and propylene (CAS Reg. No. 115-07-1) and subsequent curing with triallylisocyanurate (CAS Reg. No. 1025-15-6) or triallylcyanurate (CAS Reg. No. 101-37-1) and 2,2’-bis(tert-butylperoxy)diisopropylbenzene (CAS Reg. No. 25155-25-3) |
Jul 17, 2019 |
|
|
The FCS is a reaction product of three polymers:
REPLACES FCN 1767 |
Jul 3, 2019 |
Proposes to amend toxics limits in recycled glass packaging
Recently, a bill SB 232 was enrolled and presented to the California’s Governor which temporarily increase allowable total heavy metal limits in recycled glass packaging.
The Toxics in Packaging Prevention Act prohibits a person from offering for sale in this state a package exceeding 100 ppm of total concentration levels of lead, cadmium, mercury, or hexavalent chromium.
However this bill, if signed into law, would increase to 200 ppm the allowable levels of total heavy metals in recycled glass packaging.
The exemption would be repealed on January 1, 2024.
Please click here for more information.
Improvement proposal in the registration of products under INMETRO
On 2nd September 2019, the National Institute of Metrology, Quality and Technology – INMETRO notified to World Trade Organization (WTO) their proposal Ordinance 404, 28 August 2019.
It proposes improvements in the criteria and procedures for the registration of products, inputs and services under INMETRO's regulatory scope and which compliance is compulsorily assessed. It would revoke INMETRO Ordinance 512, 11 November 2016.
Click here for getting the notification through the European Commission website with reference G/TBT/N/BRA/907.
Draft standard for printing inks in food contact materials
On 9th August 2019, the Ministry of Consumer Affairs, Food and Public Distribution published a draft standard on printing inks for food packaging (CHD 14 (14457) WC).
The consultation was opened until 8th September 2019.
Download the document here.
Microplastics in drinking water
On 22nd August 2019, the World Health Organization (WHO) published a report on microplastics in drinking water (tap and bottled drinking-water and its sources) and their potential health impacts.
For example, Polyethylene terephthalate (PET) and polypropylene (PP) are the most frequently detected microplastic particles in fresh water. Some of these microplastics may come from treatment and distribution systems and/or the bottling process.
The WHO has called for more research into the issue to better understand and minimize the sources of plastic pollution
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 15 alerts regarding food contact materials have been reported, from 21th August until 20th September of 2019.
|
Product |
Substance / Hazard |
|
|
Nylon serving ladles |
Migration of primary aromatic amines (anilin: 91 & 4,4'MDA: 11600 µg/kg - ppb) |
|
|
Bamboo dining set for children |
Melamine (3.88 mg/kg - ppm) |
|
|
Plastic thermos |
Missing import declaration |
|
|
Bamboo cups |
Migration of melamine (3.33 mg/kg - ppm) |
|
|
Polypropylene accessories in cookware set |
Migration of primary aromatic amines (5.577, 5.356, 4.701 mg/kg - ppm) |
|
|
Bamboo dishes |
Too high level of overall migration (31.7 mg/dm²) |
|
|
Lids of thermo metal mugs |
Migration of benzene (5.7 mg/kg - ppm) |
|
|
Coffee cups |
Migration of melamine (between 8.3 and 11.8 mg/kg - ppm) |
|
|
Fixed blade knife |
Migration of chromium (1 mg/kg - ppm) |
|
|
Egg whist |
Migration of chromium (4.3 mg/kg - ppm) |
|
|
Plastic coated paper plates and cups |
Too high level of overall migration (28 mg/dm²) |
|
|
Tea filter |
Migration of chromium (3.5 mg/kg - ppm) |
|
|
Chromed iron grid |
Migration of nickel (0.5 mg/kg - ppm) |
|
|
Chromed steel grid |
Migration of nickel (0.8 mg/kg - ppm) |
|
|
Bamboo pots |
Migration of formaldehyde (71 mg/kg - ppm) |
|
From on 21th August until 20th September of 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 German language
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.
Seminar "Sustainability of food packaging" in German language
What does the market offer? Whats about biodegradation and recycling? How to communicate and ensure legal compliance?
On November 14th you will learn more about sustainability of food packaging at our German speaking seminar.
