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Food for Thought
April 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.
Confirmed: upcoming consultation on food contact material legislation revision to be published 'soon'

During the Chemical Watch Food Contact Regulations Europe 2022 conference on 29th March, a European Commission policy officer announced that the Commission is working on a public consultation on the revision of the food contact material legislation. The consultation will be a questionnaire and is expected to be published 'soon'.

The officer confirmed the revision will address all types of food contact materials, and take a more restrictive approach on the most hazardous chemicals, including endocrine disrupting chemicals (EDCs), chemicals that are carcinogenic, mutagenic and toxic for reproduction (CMRs), and chemicals that are persistent, bioaccumulative and toxic (PBTs).

Focus groups provide insight on consumer views of food contact materials

The Federation of German Consumer Organisations (Verbraucherzentrale Bundesverband – vzbv) released the results of focus group interviews held in Germany in September 2021, in which consumers were asked about their expectations and attitudes towards food contact materials. The results provide an insight into how consumers understand the safety of food contact materials.

The consumers surveyed assumed that government regulations protect consumer health through comprehensive safety testing prior to allowing a product on the marketplace. Unfortunately, studies have shown that this is not the case, and that hazardous chemicals are present in food contact materials currently on the market. Those surveyed did not have sufficient information regarding the risks of harmful chemicals in food contact materials, and as a result downplayed the risks of chemicals in food packaging. The survey also suggests that consumers base their purchases on routines and learned behaviours, indicating an increased need for stricter regulation at the national and supranational levels.

VZBV presented their policy recommendations alongside the results of the focus groups. Their positions include: finalising the revision of the Food Contact Materials Regulation (EC) No 1935/2004 and including in that revision a clear ban on the most harmful substances; implementing an approval and registration process; strengthening monitoring and enforcement; and developing more comprehensive and clear guidelines for consumers. 

New review shows chemicals migrate from PET bottles into beverages

As the European Union continues to consider a newly revised draft proposal on uses of recycled plastic in food contact materials, a new review found that while potentially harmful chemicals are present in both newly manufactured and recycled bottles, those made of recycled Polyethylene Terephthalate (PET) can contain higher levels of potentially harmful chemicals than those made of new PET.

The study, undertaken by researchers at Brunel University in London, reviewed 91 studies that analysed PET beverage containers to determine the migration of chemicals into the drinks. They found that 150 chemicals of 193 investigated migrated into the drinks, which included water, juice, soda, and milk, among others. Of these 150 chemicals, 18 were measured at levels higher than current EU regulations allow and only 41 are included on the EU’s food contact materials 'positive list' of approved chemicals.

The authors drew attention to the potential presence of non-intentionally added substances (NIAS) in PET. These substances are harder to study and their effects on health can be unknown.

PET is 'the third most widely used type of plastic in food packaging', and a popular material for beverage containers. The study authors advocate for processes which would more thoroughly clean the plastics intended for recycling, but emphasised that the best solution is to phase out the use of PET altogether.

Updated UP Scorecard helps consumers make informed choices about food packaging

The latest version of the Understanding Packaging (UP) Scorecard, an online tool that assesses the sustainability impacts of food packaging and foodware, is now available.

The scorecard helps consumers assess different products, such as takeaway containers, hot beverage cups and aluminium cans, and make informed choices about which products to use. The tool allows consumers to select different food packaging or foodware and compare their scores for each of the six metrics: chemicals of concern, plastic pollution, climate, water use, sustainable sourcing, and recoverability.

The Chemicals of Concern (CoC) metric is calculated by adding together two different scores for:

1) Presence Score – rewards a product that claims to not use substances on the Food Chemicals of Concern List and for the level of verification that can be provided for this claim.

2) Inertness Score – rewards a product for using materials with a high level of inertness, which indicates the likelihood of any present chemicals to migrate from the material into food and the environment.

This metric 'helps users be proactive and go beyond the currently inadequate regulatory requirements to address hazardous chemicals that are knowingly still being used today in foodware and food packaging'. Learn more about the Chemicals of Concern (CoC) metric.

Try it out for yourself! Learn more about the UP Scorecard in a webinar, 'Ensuring the non-toxicity of products and packaging: a prerequisite to achieve a circular economy and protect our health', hosted by Zero Waste Europe on 5th April 2022. Watch the recording here.

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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