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PRESS RELEASE : The Food Contact Materials revision is an improvement, but still needs more work



Press release

15 April 2024



While welcoming the proposed changes to quality control rules to ensure food safety In food contact materials (FCMs), the R3PACK Consortium believes that the revision does not go far enough to protect European consumers. In particular, the consortium has three concerns regarding: the lack of attention on final articles; the lack of scientific and political scrutiny in the risk assessment procedure; the lack of mechanisms to contro endocrine disruptors In FCMs.


Following public consultations, new changes have been proposed in the ongoing revision of the EU legislation on Food Contact Materials (FCMs). These new standards are a step in the right direction, yet more can and should be done to ensure the safety of European citizens.

The legislation itself governs the safety principles of all materials that come into contact with food, such as packaging containers, kitchen equipment, cutlery, and dishes. It requires that materials do not release their constituents into food at harmful levels or change food composition in an unacceptable way. A revision was announced in 2020 to improve food safety and public health, specifically by reducing the use of hazardous chemicals through sustainable packaging solutions (packaging that is environmentally-friendly, reusable, made with recyclable materials, etc.).


Public consultations were held between 2022 and 2023 to gather feedback from stakeholders, ultimately resulting in the further improvements to the proposed revision. This includes new standards for the purity of (plastic) materials recovered from waste and natural sources. It also includes updated testing methods for multi-layer materials, as well as a requirement for repeated testing to ensure consistent safety over time. These changes align with the broad goals of the original revision proposal, such as protecting public health, however, that does not mean they are without fault.


R3PACK welcomes the newly proposed changes to quality control rules yet believes that the revision does not go far enough to ensure food safety for all Europeans. Specifically, the consortium has three major concerns regarding the revision’s rules:


1.     Lack of attention on final articles

Current proposals focus too much on the initial substances and recycling processes, and not enough on the final product that comes into contact with food. Non-Intentionally Added Substances (NIASs) are particularly worrisome in this regard, as they are contaminants/by-products from manufacturing or recycling that end up in the final product. These are difficult to characterise, making them a challenge for safety assessments, something especially true for recycled plastics which accumulate more chemicals through multiple recycling cycles and are hard to fully clean of contaminants.


2.    Lack of scientific and political scrutiny in the risk assessment procedure

It is necessary for there to be independent scientific reviews to increase the transparency and objectivity of the risk assessments. Furthermore, data should be collected by non-industry entities that work in collaboration with independent research centres to ensure unbiased assessments.


3.    Lack of mechanisms to control endocrine disruptors in FCMs

Endocrine disruptors are chemicals that can interfere with the body’s endocrine system and produce adverse developmental, reproductive, neurological, and immune effects. Despite being recognised as potential health hazards, their effects are not addressed under the current proposals. Furthermore, low-level exposures to potential endocrine disruptions often go untested due to thresholds below toxicologically established levels. These gaps need to be addressed in the proposed revision to ensure that FCMs are free from endocrine disruptors.


In conclusion, while the proposed revisions represent progress and a step in the right direction when it comes to enhancing food safety and protecting European citizens, there remain pertinent concerns, most notably regarding the three issues outlined above. Addressing these is imperative for ensuring comprehensive food safety regulation across Europe.

About R3PACK

R3PACK - Reduce, Reuse, Rethink PACKaging: towards novel fiber-based packaging and reuse schemes uptake is a project funded by the European Union’s Horizon Europe Research and Innovation Programme under Grant Agreement No 101060806. The project aims to secure the fast and extensive uptake of industrially relevant, cross-sectorial, cost-effective innovative technologies allowing immediate substitution of complex multilayer plastic packaging with high performing fiber-based packaging and economical, industrial and environmental optimisation of reuse schemes demonstrated at large scale and transnationally in 3 EU countries by 2 major retailers, covering the needs of 13 different food product types









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