The Chemical Strategy for Sustainability (CSS) envisions better coordination and distribution of tasks between EU agencies like EFSA and ECHA concerning the hazard and risk assessment of substances. This translates in the aspirational approach of ‘one-substance, one-hazard-assessment’ (OSOA) followed by a tailored risk assessment as suggested by various stakeholders of the packaging value chain. This approach could be incorporated in the ongoing review of food contact materials and articles (FCMA) legislation. Such an approach has the potential of greatly improving the assessment process for substances used in FCMA across Europe for the future. With this paper, stakeholders of the packaging value chain offer a reflection on the OSAO concept and the need for tailored risk assessments for FCMA
The EU Commission has published an Inception Impact Assessments on the EU rules on food contact materials to inform citizens and stakeholders about its plans. In a joint feedback the associations of the Packaging Ink Joint Industry Taskforce (PIJITF) welcome the Inception Impact Assessment and support the objective of the new initiative. The PIJITF considers the legal framework to be fit for purpose and hence suggests that priority should be the timely development of further specific measure(s) for non-plastic materials, especially printed food contact materials. In these specific measures industry risk- assessment for non-listed substances should be incorporated.
The European Commission has published a “Study supporting the Evaluation of Food Contact Materials (FCM) legislation – (Regulation (EC) No 1935/2004)”, which was conducted by the consultant Ecorys and which provides an analysis of the current EU legislative framework for FCM. The study assesses the effectiveness, efficiency, relevance, coherence, and the EU added value of the Regulation. In a joint feedback several associations of the food packaging chain acknowledge the work performed by Ecorys and offer comments and solutions to key points identified in the report regarding food contact materials (FCM).
The EU Commission had announced its intention to adopt new Union legislation which has in scope the printing ink layer as part of printed food contact materials (“pFCM measure”). The Commission invited the Packaging Ink Joint Industry Task Force (PIJITF) to contribute to the process.
The PIJITF represents the members of the food packaging supply chain that are concerned with the application of printing inks onto food contact materials and their subsequent use. Although the Commission has meanwhile put its work on the pFCM measure on hold due to a general evaluation of the regulatory framework for food contact materials, the PIJITF wishes to present to and discuss with stakeholders its position paper which outlines the key elements that should be considered when drafting the EU measure. These elements ensure a high degree of consumer safety whilst they are pragmatic and workable for industry.
In a joint feedback several associations of the food packaging chain welcome the roadmap on the “Farm to Fork Strategy” and support the transition to a sustainable food system which contributes to climate neutrality and the circular economy. Food contact materials and articles are an essential part in the food supply chain and play a key role to ensure consumers safety and for the overall sustainability of the food system. Therefore, the associations call on the Commission to integrate the EU harmonised approach towards food contact materials in the Farm to Fork Strategy and ensure its timely development.
