Food safety requirements
Check recommendations, normalization, regulation requirements
National and European regulations manage the chemical risk linked to the migration of substances from the packaging. The packaging must comply with the food regulations "Food Law" (Regulation (EC) No 178/2002) which aims to reduce, eliminate or avoid health risks, in particular, microbiological and chemical risks (e.g. chemical substances) from packaging materials, cleaning residues, physical (e.g. micro-plastics, foreign bodies) and food residues. The framework regulation (EC) n ° 1935/2004 of materials in contact with food (FCM) generally covers the chemical inertia of materials intended to be in direct/indirect contact with food "... so as not to give up constituents to these foodstuffs in quantity liable to present a danger to human health… ”. Depending on the nature of the FCM considered (17 groups according to annex I of the framework regulation covering plastics, glasses, ceramics, rubbers, etc.), there are a large number of European or national texts, the most supervised and harmonized of them concerns plastic materials.
Satisfy rules to prevent chemical risk associated with migration.
Depending on the nature of the FCM considered (17 groups according to annex I of the framework regulation covering plastics, glasses, ceramics, rubbers, etc.), there are many European or national texts, the most supervised and harmonized of them concerns plastic materials. Indeed, only 4 materials (plastics, ceramics, regenerated cellulose films and active and intelligent materials) out of the 17 referenced in annex I of the framework regulation are covered by a harmonized regulation.
PLASTICS - Regulation (EU) No. 10/2011 and its amendments bring together a set of criteria to be observed for plastics in contact with food, in particular: i) composition criteria with the "EU list"; ii) purity criteria, iii) migration test conditions and migration limits as well as iv) criteria for establishing the Declaration of Compliance (DoC). Exposure levels can be assessed by migration tests but also by calculations as defined in Regulation (EU) No 10/2011. The two approaches overestimate the real level of migration, either by an excess simulation of the real contact conditions (by a food simulant, a time and a temperature) or by "worst case" calculation scenarios (complete migration or application of diffusion models). Moreover, recycled plastics by a mechanical recycling process must also comply with Regulation (EC) No 282/2008, which requires, among other things, to carry out a challenge test to prove the decontamination of these materials and an assessment of the process by EFSA.
For OTHER FCMs not covered by a harmonized EU regulatory text, professional recommendations and guides, as well as laws, are defined at the Member State level to meet the principle of consumer protection. The various non-harmonized laws of the EU Member States are, of course, managed by mutual recognition (Regulation (EU) No 2019/515). In France, the DGCCFR and its working groups are developing recommendation sheets for analysis laboratories and manufacturers. This is also the case with BfR recommendations in Germany.