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Food for Thought
March 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.
NGO letter on harmful chemicals in recycled plastic food packaging

Zero Waste Europe, CHEM Trust and 26 other civil society organisations across Europe have sent an open letter to the EU Commissioner for Health and Food Safety, Stella Kyriakides. The letter sets out their concerns about proposals in the new draft Regulation about the placing on the market of plastic materials and articles containing recycled and secondary plastic, intended for use in food packaging.

A large body of evidence shows that compared to virgin plastics, recycled plastics almost always contain higher levels of hazardous substances. Some of these substances can migrate into food and then cause harm to human health.

The letter calls for caution and a strong regulatory framework to prevent toxic recycling which will anticipate future regulatory changes, and urges the Commission to revise the current draft and delay its adoption.

As a matter of priority, the Commission should urgently proceed with the revision of the Food Contact Materials Regulation Framework, to ensure the elimination of hazardous chemicals in virgin materials in the first place.

Chemicals not included in new global plastic pollution resolution

On 2nd March, 175 countries adopted a UN resolution, 'End plastic pollution: Towards an international legally binding instrument', which aims to improve the design of plastics and recycling and could also include curbs on plastic production.

Disappointingly, a reference to the risk that chemicals in plastics pose to people's health and the environment was removed from the resolution.

However, chemicals can still be discussed during treaty negotiations. These will take place over the next couple of years. In order to protect people's health and environment, it is vital that hazardous chemicals are included in these upcoming negotiations.

US petition on Bisphenol A

After the European Food Safety Authority (EFSA) proposed a significantly lower tolerable daily intake (TDI) for bisphenol A (BPA), a group of American doctors, scientists and organisations working on health and environmental issues launched a petition demanding similar action from the FDA (US Food and Drug Administration).

The petition calls for a limit of BPA in food contact materials to less than 0.5 parts per trillion in food, and asserts that the average American is 'exposed to more than 5,000 times' the new safe level identified by EFSA.

Maricel Maffini, a co-author of the petition, echoed the perspective of EFSA: "What we are seeing now is that the levels that we thought were safe – they don’t seem to be safe, and the levels that we identify as causing problems in the immune system are incredibly low."

CHEM Trust submitted comments on EFSA's draft re-evaluation of the BPA TDI, welcoming the re-evaluation and highlighting the need to also assess the risks of other bisphenols which have shown similar adverse effects.

Upcoming webinar on the circular economy and non-toxic products

On 5th April, Zero Waste Europe is hosting a webinar 'Ensuring the non-toxicity of products and packaging: a prerequisite to achieve a circular economy and protect our health'.

The webinar will answer these key questions:

  • How does the presence of hazardous chemicals in products impact our health? 

  • How zero waste solutions are contributing to minimising exposure to hazardous chemicals? 

  • What can the EU do to ensure clean materials streams, achieve a toxic-free circular economy and protect people’s health?

Find out more and register to attend the webinar 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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