Plastic Food Contact Materials in Europe: Proposal to Update Quality Control Rules

On March 13, 2024, the European Commission (EC) has released an initiative to seek feedback on the proposal to update quality control rules for plastic food contact materials (FCMs).

This draft regulation aims to increase quality control under Regulation (EU) No 10/2011 on plastic FCMs by:

• Ensuring alignment with Regulation (EU) 2022/1616 on recycled plastics and Regulation (EU) No 528/2012 on biocidal products.
• Introducing purity requirements for substances obtained from waste and natural materials.
• Adapting migration testing of multi-layer materials and repeat testing.

It also adds quality control rules to Regulation (EC) No 2023/2006 on good manufacturing practice.

The potential changes compared to the legislation currently in force are:

• Insertion of the parameter according to which, for articles intended for repeated use, the composition of plastic materials and articles shall be such, to guarantee that no increase in the migration of constituents of the material or article to the food would occur during their maximum life span when subjected to subsequent use cycles.
• Obligation to report on the label, for articles for repeated use, information about its maximum lifespan, information to mitigate deterioration of the article and a description of the visual changes that indicate deterioration and reaching the end of life, as well as any restrictions in the use of the article.
• Request in the declaration for information regarding impurities present in the raw materials used.
• Request in the declaration information about the “maximum lifespan” of the article - Introduction of the concept of high purity degree for raw materials.
• Introduction of the possibility by the relevant authorities to take samples to verify their degree of purity and their composition, including that of the substances and materials used for their manufacture. (intermediate stages materials)
• New reference to plastic wastes (if used in the production, they shall be of a high degree of purity and shall be of a technical quality suitable for the intended and foreseeable use of the materials or articles.)
• Introduction of new details in the declaration in the case of use of plastic wastes and reprocessing materials.
• Applicability of the tests established by Regulation 10/2011 and further amendments also to plastic layers in multi-material multi-layer materials.

If the law comes into force, business operators will have to revise the declarations for their products in contact with food intended for repeated use, aligning it with the new provisions, as well as the labels that accompany the products. Particular attention must also be paid to the declarations submitted by raw material suppliers, which must comply with the new provisions.

UL Solutions can support you in assessing the correctness of the labeling affixed to food contact materials, as well as the formal correctness of the declarations received by raw materials suppliers.

We can also help your business by performing analytical tests and checking the declaration of compliance for the product in its finished form.

Source

Food safety – plastic food contact materials (FCMs) (update to quality control rules)