October 16, 2020
Following UL’s webinar “EU: Chemical Safety Highlights for Food Contact Materials”, where we discussed such topics, we interviewed UL subject matter expert, Luca Foltran, to provide you with further insights into food contact compliance in the EU market.
Below you will find the complete interview.
Question: You spoke about the Declaration of Compliance (DoC) for the European market. What legal information must be included in the DoC for a food contact material in finished form?
Luca: The DoC must apply to the entire product, and therefore it must also take into account all the parts used in the food contact materials, and also, for example, the colorants used in the product. The entire material must comply with the general requirements of Framework Regulation (EU) 1935⁄2004 and the declaration must include assurance to this effect. In addition, the declaration must demonstrate safety references for all parts of the food contact material. If the material consists of a single constituent, only one safety reference, e.g., Plastics Regulation, may be indicated. If, for example, the contact material is made of several materials or layers of material, a safety reference must be demonstrated for each of these separate materials or layers. To give an example, if the material is printed, plastic-coated board, a safety reference must be indicated for the board, plastic and printing inks.
Question: From which authority can a DoC for food contact material be obtained?
Luca: Authorities do not issue DoC for food contact materials. The manufacturer and the importer are responsible for issuing it. It is the manufacturer who has the best knowledge of the product composition and the manufacturing process, and who must have requested and performed testing on food contact material to establish whether or not constituents in the material migrate into the food and the amounts involved. The importer must request the manufacturer to provide a DoC when the import phase begins.
Question: Does Plastics Regulation (EU) 10/2011 apply to multilayer materials in which one of the layers is plastic, but the other layers are other materials?
Luca: In a multi-layer food contact material, where only one layer is plastic and the other layers are composed of other materials, the Plastics Regulation applies only to the plastic layer in respect of restricted substances. Multi-layer material (from this totality) is not required to comply with the limits requested by the Plastics Regulation.
Question: Are there special restrictions on the use of recycled plastic in the manufacturing of food contact materials? What requirements does recycled plastic have to meet?
Luca: The use of recycled plastic obtained from a mechanical recycled plastic process is not currently possible in food contact applications, other than possibly behind the barrier. The European Commission currently has more than 100 plastic recycling processes for authorization, almost all concerning the recycling of PET, and the commission is now working on authorization decisions. Once plastic recycling processes have been authorized, the use of material from that process may begin.
The finished recycled plastic must meet the requirements of Plastics Regulation (EU) 10/2011.
Question: Why don’t all food contact materials have a glass-and-fork symbol indicating their suitability for food contact?
Luca: The glass-and-fork symbol appears in Annex II of the Framework Regulation to indicate the use of a material for contact with food.
Its use is voluntary, and suitability for contact with food can also be stated in other ways, such as:
- Other similar symbols (coffee machine, wine bottle or soup spoon)
- The text “for food contact”
- Naming the contact material according to its use, for example, by labeling
If the intended use of a material or article to come in contact with food is not sufficiently well shown, they will not be specified with a symbol as a food contact material.
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