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Food for Thought
October 2020
Welcome to 'Food for Thought', a newsletter sharing key updates on food contact material (FCM) policy, ideas for revised FCM legislation and useful resources.

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.

There are thousands of chemicals in food contact materials that can potentially migrate into our food or drink. In Europe alone, some 8,000 chemicals can be used in articles packaging our food. But many of these chemicals can harm our health and pollute the environment. This is why we need more protective regulation. 
Upcoming opportunities to ensure legislation on food contact materials protects health and the environment from harmful chemicals

The EU Commission's Chemicals Strategy prioritises action on food contact materials

On 14th October the European Commission published its Chemicals Strategy for Sustainability, as part of the EU's zero pollution ambition in the European Green Deal. The strategy sets out clear measures to prohibit the use of harmful chemicals in consumer products, including in food contact materials.

With this new strategy, food contact materials have been given high priority on the Commission's agenda as part of the overarching strategy to guide future chemicals policies in the EU. In the action plan accompanying the Chemical Strategy, the Commission commits to:

  • Proposals to extend the generic approach to risk management to ensure that consumer products (including food contact materials) do not contain chemicals that cause cancers, gene mutations, affect the reproductive or the endocrine system, or are persistent, bioaccumulate and toxic;
  • Proposals to assess the modalities and timing to extend the same approach to further chemicals, including those affecting the immune, neurological or respiratory systems and chemicals toxic to a specific organ;
  • Updated information requirements to allow the identification of endocrine disruptors in relevant legislation, particularly under REACH and legislation on food contact materials;
  • The introduction or reinforcement of provisions to take account of the combination effects of chemicals in water, food contact materials, food additives, toys, detergents, and cosmetics. 
These are significant commitments, and we believe that with this strategy the Commission has decided on a good direction for its proposal for the revision of the legislation on food contact materials, which was announced in its Farm to Fork Strategy.

See CHEM Trust's and the Health and Environment Alliance (HEAL)'s responses to the Chemicals Strategy, encouraging the European Commission to act swiftly and avoid delays in implementing the strategy.

Upcoming Inception Impact Assessment provides a key opportunity to continue ambition

The next step towards improved food contact materials legislation will be the publication of the EU Commission's Inception Impact Assessment (IIA) for the reform of the legislation. The IIA is expected within a few weeks. We hope that it continues the ambition set out by the Chemicals Strategy.

In the IIA, the Commission is expected to present a number of policy options for the revision of the legislation. These should include options for how it will fulfil the above commitments and also present possible solutions for issues that are still outstanding, such as the need for harmonisation of the rules for a wider range of materials that come into contact with our food, and how to ensure that in the future we will have basic knowledge and adequate safety assessments for all harmful chemicals in food contact materials, including the so called NIAS (Non-Intentionally Added Substances).

New OECD report highlights alternatives to PFAS in food contact materials

A new report published by the Organisation for Economic Co-operation and Development (OECD) shows that alternatives to Per- and polyfluoroalkyl substances (PFAS) in food contact materials are available on the market. 

Commonly used in food contact materials because of their grease and water-resistant properties, some PFAS are known to be endocrine disrupting chemicals (EDCs) and have been linked to a wide range of serious health concerns. See this joint briefing for more information on PFAS.

The new EU Chemicals Strategy includes plans to address the use of PFAS, including in consumer products and non-essential uses. A number of brands and retailers have already committed to move away from PFAS in their products, by signing up to ChemSec's corporate PFAS movement.

The report states that non-fluorinated alternatives to PFAS are already available on the market, and that they can meet the grease and water-resistant needs for common food packaging uses.

New website by CHEM Trust offers actions to take on chemicals in food contact materials

CHEM Trust has launched a new website all about endocrine disrupting chemicals (EDCs), with information on how they can impact human health and the environment. It offers advice on how to limit your risk of exposure to endocrine disruptors, including from food contact materials.

In addition to information on EDCs, the website highlights some actions that consumers can take on harmful chemicals in food contact materials in both the UK and the EU.

Check out resources from the Food Packaging Forum's 2020 workshop

On 21st-23rd October the Food Packaging Forum held their 2020 workshop online, focusing on the theme 'Improving the chemical safety of food contact articles: Linking policy-making with scientific research'.

If you didn’t manage to join the workshop live, check out the presentations that are available on the Food Packaging Forum website, including HEAL's Natacha Cingotti's presentation titled 'Revising European FCM regulations: Efforts from a NGO coalition'.

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, businesses, experts, and change agents working towards the same vision: phasing out waste from our society. We empower communities to redesign their relationship with resources, to adopt smarter lifestyles and sustainable consumption patterns, and to think circular. (EU Transparency number: 47806848200-34)
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