Politics & Legislation

European Consumer Organisations Call for Regulation on Paper and Board Food Contact Materials

While these materials are essential to how we transport, preserve, and ultimately consume our food, they may also negatively impact the quality and safety of foodstuffs.

On its way from farm to fork, our food comes into contact with many different materials and products, such as food processing machines, plastic packaging or paper wraps, kitchen aids and ceramic tableware.

While these materials are essential to how we transport, preserve, and ultimately consume our food, they may also negatively impact the quality and safety of foodstuffs.

Chemicals present in food contact materials (FCM) are known to migrate into, and thus contaminate foodstuff, thereby potentially creating risks for consumer health.

Existing EU legislation is meant to safeguard consumers against such risks; however, the current rules are deficient and provide insufficient protection of consumers.

Previous tests by European consumer groups have thus highlighted2 the problematic use in paper and board food packaging of fluorinated compounds, a group of chemicals with suspected adverse effects on human health.

New evidence by consumer organisations now demonstrate that chemicals of concern are also present in – and migrate from – coloured paper and board food contact materials, such as coffee cups, paper straws, printed napkins and grocery products packaged in paper or board.

These results again underscore the need for strict EU rules governing the safety of paper and board FCMs.

FCM legislation in Europe: a regulatory patchwork

According to current EU legislation, all FCMs should be safe and inert – that is, not influence the food in a negative way.

With the exception of plastic food contact materials, harmonized EU rules to determine compliance with these generic provisions have however not been established.

Consequently, demonstrating that food safety is consistently achieved for materials other than plastics has proven difficult, as illustrated by several food contamination scares3 originating from food packaging, such as cardboard.

In 2016, the European Parliament concluded4 that the lack of uniform EU rules is detrimental to public health. Parliament therefore urgently called on the Commission to achieve comprehensive, harmonized regulation of all FCMs; as a priority, Parliament emphasised in particular the need to develop EU rules for paper and board and printing inks.

Paper and board are the second most used type of FCMs in Europe, superseded only by plastics.

Specific EU legislation for paper and board FCMs does not exist, however. While Member States can adopt their own national measures in the absence of harmonized EU rules, only nine Member States have such rules in place.

Moreover, of the estimated 1,710 substances covered by these measures, only nine per cent are regulated by three or more Member States, according to a 2017 review by the Joint Research Centre (JRC).

Printing inks are primarily used on food packaging to give information to consumers about the food product or for marketing purposes.

The EU Plastics Regulation regulates the use of certain printing inks on plastic materials; for all other material types, such as paper and board, no specific EU rules exist. While some European countries, notably Switzerland have adopted national rules, there are significant difference in risk assessment schemes and regulated substances.

This regulatory patchwork implies that European consumers are not guaranteed the same level of protection against harmful chemicals in printed FCMs depending on where they live; the European Commission has thus acknowledged that the health of consumers is not adequately safeguarded with respect to printed food contact materials.

In 2017, the Commission initiated preparatory work for specific EU rules on printed FCMs, although a proposal has yet to be finalised.

A colourful cocktail: chemicals of concern in printed FCM

Food packaging inks are complex chemical mixtures of colorants (pigments and dyes), binders, solvents and additives, such as photoinitiators (i.e. UV-filters). More than 5,000 different substances are used to produce various printing inks.

Only a fraction of these substances has been systematically evaluated by EFSA; for 90%, insufficient toxicological data means that it is currently not possible to comprehensively assess their health risk.

Printing ink substances can migrate from packaging materials to food either through direct contact, from migration through food contact layers or through ‘set-off’ transfer of contaminants from one printed surface to another.

Previous research has for example shown migration of certain chemicals of concern such as primary aromatic amines or photoinitiators from printed packaging into food.

Primary aromatic amines (PAAs) are used in the manufacture of certain yellow, orange, and red colorants, but can also be present in inks as impurities or breakdown products.

Several PAAs are known or suspected to have carcinogenic properties and may therefore pose a health risk if they transfer to food. The German Federal Institute for Risk Assessment (BfR) thus recommends that consumer exposure to such PAAs should be limited to the greatest possible extent.

Photoinitiators (PIs) are highly photoactive compounds used in certain printing inks and varnishes.

PIs cover a diverse group of chemicals, including relatively well-known substances such as isopropylthioxanthone (ITX) and benzophenone. Some photoinitiators are suspected to cause cancer and/or have been linked to endocrine disrupting properties.

Benzophenone was for example recent included in the Commission’s list of potential endocrine disruptors in cosmetics.

A Consumer Survey: chemicals of concern in printed food packaging

Against this background, four consumer organisations, Altroconsumo (Italy), Forbrukerrådet (Norway), Forbrugerrådet TÆNK (Denmark), and OCU (Spain) decided to investigate the presence of PAAs as well as selected PIs and related substances in printed paper and board FCMs in different European countries.

Whereas PAAs have previously been detected in e.g. printed napkins,18 the present survey sought to investigate their presence in other types of printed paper and board FCMs as well.

Building on previous studies demonstrating migration of benzophenone and ITX from printed packaging, the survey further focused on these two well-known PIs as well as other less-investigated PIs and related substances.

The survey sampled 76 different highly printed paper and board food contact materials, such as coffee and soda cups (board), paper plates and straws, napkins, muffin forms, paper bags from bakeries and from ‘pick and choose’ candy shops, as well as paper and board packaging from grocery items like pastas, grains, and noodles.

All 76 samples were sent to a laboratory for further analysis.

Results: prevalence of PAAs and PIs in printed food packaging

All 76 samples were analysed to verify the presence of primary aromatic amines as well as selected photoinitiators, such as benzophenone. In the absence of official EU guidance values for printed paper and board FCMs, the results were assessed against the following reference values:

  • According to the Plastics Regulation, primary aromatic amines that have not been specifically assessed shall not migrate into food or food simulants in a detectable amount. The detection limit is 0.01 mg/kg or 10 µg/L and applies to the sum of released PAAs.
  • The BfR recommends that transfer of individual PAAs classified as carcinogenic category 1A or 1B should not transfer into food (or food simulants) based on an analytical detection limit of 0.002 mg/kg or 2 µg/L.
  • Annex 10 of the Swiss FCM Ordinance establishes various limits for substances used in the printing of FCM including for photoinitiators: Part A sets out specific migration limits (SMLs) for toxicologically evaluated substances, such as benzophenone (0.6 mg/kg). Part B establishes an analytical limit of 10 ppb (10 μg/kg) for non-evaluated substances.

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European consumer organisations call for action on paper and board food contact materials


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