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Food for Thought
February 2023
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.
Delays to revision of Food Contact Material legislation continue

The European Commission's public consultation on the revision of the EU's Food Contact Material legislation closed on 11th January, with 610 submissions. The Commission will now analyse the 610 submissions and set up further consultation activities, built on the responses received.

In December the Commission shared its plans to further delay the FCM law's review process, giving a deadline for a new legislative proposal as "2024 and beyond". This leaves serious questions over the continuity of this process, and when and how high protection from harmful chemicals in FCMs will be ensured.

New report on chemicals in silicone baking moulds

New tests suggest that silicone baking moulds may be contaminating baked foods with unwanted chemicals.

The study, undertaken by 10 members of BEUC (The European Consumer Organisation), tested 44 different silicone moulds purchased from physical and online stores from across the EU. The results showed that 23% of products tested either released contaminants in high amounts, or the level of contaminants released increased between tests – indicating the product was not suitable for repeated use.

82% of products contained substances of concern, including suspected endocrine disruptors. Even though these were found at low levels they contribute to our overall exposure to multiple harmful chemicals from different sources, known as the cocktail effect.

Read the study here.

Zero Waste Europe calls for phase out of PVC in food contact materials

The European Commission has asked the European Chemicals Agency (ECHA) to prepare a report on polyvinyl chloride (PVC) and its additives, which is expected in May 2023. ECHA issued a call for evidence to collect information for the report at the end of 2022.

Zero Waste Europe (ZWE) responded to the call for evidence and emphasised the need for a restriction on use of PVC in food packaging and other food contact materials. ZWE argues that existing certainties about the negative impact of PVC and its additives on human health and environment throughout its whole life cycle - coupled with serious uncertainties about the circularity of PVC and (very high number of) associated chemicals - require decisive actions. They highlight that there are several technically feasible, and commercially available, alternatives to PVC packaging.

Efforts to remove bamboo food contact materials from the EU market

At the end of November, the European Commission, together with the EU Agri-Food Fraud Network, published the results of a coordinated enforcement action on plastic food contact materials (FCM) containing bamboo.

The action aimed to put an end to the illegal import, trade and advertising of plastic articles containing bamboo and other unauthorised plant-based additives that are sold as food contact materials. These additives may not have been safety assessed for their use in plastics and may therefore present a health risk. The addition of bamboo to plastic food contact materials can lead to the accelerated degradation of the plastic, and the leaching of formaldehyde and melamine into food, sometimes above safe levels. Melamine has recently been added to the candidate list of substances of very high concern (SVHC) under the REACH regulation.

Key policy updates

New CLP hazard classes: The European Commission has adopted proposals to update the EU regulation for the Classification, Labelling and Packaging of chemicals (CLP), to include hazard classes for: suspected EDCs; chemicals with persistent, bioaccumulative and toxic (PBT) properties; and very persistent and very bioaccumulative (vPvB) properties. Read more here.

PFAS restriction proposal submitted: Denmark, Germany, the Netherlands, Norway and Sweden have submitted a proposal to restrict PFAS under REACH to the European Chemicals Agency (ECHA). PFAS have been linked to serious health concerns but are used in food packaging and other food contact materials due to their grease and water resistant properties. Read more here.

EFSA final assessment of BPA delayed: The European Food Safety Authority (EFSA)'s final assessment of Bisphenol A (BPA), previously expected to be published in December 2022, has been delayed to 2023. Read more 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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