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Food for Thought
February 2022
Welcome to 'Food for Thought', a newsletter sharing key updates on food contact material (FCM) policy, ideas for revised FCM legislation and useful resources. There are thousands of chemicals in food contact materials that can potentially migrate into our food or drink, and many of these chemicals can harm our health and pollute the environment. This is why we need more protective regulation.
EFSA proposes to lower tolerable daily intake for BPA

The European Food Safety Authority (EFSA) has published a draft re-evaluation of bisphenol A (BPA), proposing a significant reduction in the tolerable daily intake (TDI) for BPA.

BPA is widely used in the production of plastic food contact materials, such as plastic tupperware and food can liners, and can migrate out of the materials and into the food we eat. It is a known endocrine disruptor and has been linked to a range of health impacts including reproductive issues, obesity, cancer and negative impacts on brain development. Studies have shown it can have an impact at extremely low levels.

The current temporary TDI for BPA, set in 2015, is 4 micrograms per kilogram of body weight per day. The proposed new TDI would reduce this by 100,000 times to 0.04 nanograms per kilogram of body weight per day. The reduction is in response to an assessment of studies that have emerged since 2013 until 2018, particularly studies that indicate adverse impacts of BPA on the immune system.

The proposal will not apply to substitutes for BPA, such as bisphenol S and bisphenol F. These substances, which have similar properties and a similar hazardous profile to BPA, are a very good example of 'regrettable substitution' - when chemicals or chemical groups are substituted with problematic alternatives.

EFSA's draft proposal is open for comments from interested parties until 22nd February 2022.

EU Court rules that BPA must be listed as a substance of very high concern

The Court of Justice of the EU has ruled that BPA must be listed as a substance of very high concern (SVHC) due to its hormone-disrupting properties on the human body.

The European Chemicals Agency (ECHA) added BPA to the SVHC list under REACH for its hormone-disrupting properties in 2017. The lobby group PlasticsEurope's tried to overturn this listing, but the Court rejected their final attempt to reverse ECHA's decision. Listing a chemical as an SVHC triggers requirements for manufacturers to communicate information about the chemical to consumers, and sends a signal to industry to move to alternatives.

PlasticsEurope has taken ECHA to court on three separate occasions. In all three cases, ClientEarth acted as an intervener, supporting ECHA in its defence, together with France and Germany, against PlasticsEurope's challenge before the EU courts.

Harmful mineral oils found in food across Europe

New tests conducted by the NGO foodwatch have found mineral oils in food products from across Europe.

152 food products from Austria, Belgium, France, Germany and the Netherlands were tested, and 1 in 8 (19 in all) food products were found to be contaminated with mineral oils. Aromatic mineral oils (MOAH) are derived from crude oil, and suspected by the European Food Safety Authority (EFSA) to be carcinogenic and genotoxic. foodwatch states that sources of mineral oil contamination include food packaging as well as machines and procedures used during the harvesting and processing of food.

foodwatch has launched a petition, that has already been signed by over 73,000 citizens, to the EU Commissioner for Health and Food Safety Stella Kyriakides and the decision makers of the EU Member States, calling for a zero-tolerance rule for MOAH contamination in all food categories across the EU.

This newsletter is produced by a collaboration between CHEM Trust, the Health and Environment Alliance (HEAL) and Zero Waste Europe (ZWE). Together, we are working towards creating a toxic-free environment where nobody should have to worry about the presence of health-harming chemicals in the products that come into contact with our food.

CHEM Trust is a charity based in Germany and the UK, with the overarching aim to prevent synthetic chemicals from causing long term damage to wildlife or humans, by ensuring that chemicals which cause such harm are substituted with safer alternatives. (EU Transparency number: 27053044762-72)

The Health and Environment Alliance (HEAL) is the leading not-for-profit organisation addressing how the environment affects human health in the European Union (EU) and beyond. HEAL works to shape laws and policies that promote planetary and human health and protect those most affected by pollution, and raise awareness on the benefits of environmental action for health. (EU Transparency number: 00723343929-96)

Zero Waste Europe (ZWE) is the European network of communities, local leaders, experts, and change agents working towards the elimination of waste in our society. We advocate for sustainable systems and the redesign of our relationship with resources, to accelerate a just transition towards zero waste for the benefit of people and the planet. (EU Transparency number: 47806848200-34)
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