Food contact materials
Materials and articles which are intended or reasonably to be expected to come into contact with food, such as food packaging, kitchen equipment, glassware, cutlery and dishes, are all considered to be food contact material.
These products can be made from a variety of materials including plastics, glass, paperboard and metal. These materials must be manufactured and processed in compliance with EU regulations, including good manufacturing practices, so that any potential transfer (migration) of chemical substances into the food during use does not raise any safety concerns, change the composition of the food in an unacceptable way or have any adverse effects on the taste and/or odour of foods.
European legislation
Regulation (EC) 1935/2004 provides the harmonised legal framework for food contact materials in the European Union. It sets out the following general principles of safety for all food contact materials:
- Food contact materials should not release their constituents into food at levels harmful to human health;
- Food contact materials should not change the food composition, taste and odour in an unacceptable way;
- Labelling, advertising and presentation of a material or article shall not mislead the consumers;
- All food contact materials shall be manufactured according to good manufacturing practice.
- Materials and articles must be accompanied by a Declaration of Compliance.
Labelling
Article 15 of the regulation specifies the labelling requirements. It says that food contact materials shall be accompanied by the words “for food contact” or the symbol below, unless when it is obvious that the article is for food contact:
Article 11 of Regulation (EC) 450/2009 on active and intelligent food contact materials has additional rules on labelling. Consumers are informed of non-edible parts whenever they are perceived as edible with the words ‘DO NOT EAT’ and with the following symbol:
GMP: Good manufacturing practice
Regulation (EC) 2023/2006 provides the details on how to comply with the general principle of good manufacturing practice, for example:
- Production facility should be suitable for food contact manufacturing ;
- Production staff should be aware of risk of critical production stages and risks should be managed appropriately;
- Quality assurance and quality control systems should be documented and available at the facility;
- Only suitable (starting) materials shall be used with regards to the safety of the final products.
Good manufacturing rules apply to all stages throughout the whole manufacturing process. Quality systems like ISO 9000 control that products are produced according to procedures and specifications. Such quality systems may provide a basis for ‘good manufacturing practice’, but it is only sufficient if the good manufacturing practice principles are applied in addition. Good manufacturing practice ensures that all products are safe for the intended food contact use.
Material-specific legislation
Annex I of Regulation (EC) 1935/2004 lists seventeen material groups that are subject to specific measures.
Only four out of seventeen material groups are covered by EU legislation.
The majority of EU Member States have adopted their own national laws for food contact materials without specific EU measures. The regulated material groups and requirements differ from one Member State to another.
Finally, the Council of Europe (CoE) has published recommendations for some food contact materials.
The seventeen material groups listed in Regulation (EC) 1935/2004 are:
- Active and intelligent materials – EU Regulation (EC) 450/2009
- Adhesives
- Ceramics – EU Directive 84/500/EEC
- Cork – CoE Resolution ResAP(2004)2
- Glass
- Ion-exchange resins – CoE Resolution ResAP(2004)3
- Metals and alloys – CoE Resolution CM/Res(2013)9
- Paper and board – CoE Resolution ResAP(2002)1
- Plastics (including recycled plastic) – EU Regulation (EU) 10/2011
- Printing inks – CoE Resolution ResAP(2005)2
- Regenerated cellulose film (RCF) – EU Directive 2007/42/EC
- Rubbers – CoE Resolution ResAP(2004)4
- Silicones – Coe Resolution ResAP(2004)5
- Textiles
- Varnishes and coatings – CoE Resolution ResAP(2004)1
- Waxes
- Wood
For more information on food contact material legislation in the EU, please visit:
https://ec.europa.eu/food/safety/chemical_safety/food_contact_materials/legislation_en.
Technical expert guidelines on food contact materials are available from the European Commission’s Joint Research Centre (JRC) and the European Union Reference Laboratory for Food Contact Materials (EURL-FCM):
https://ec.europa.eu/jrc/en/eurl/food-contact-materials/technical-guidelines
