![]() Since then, the Council of Europe has also been working on draft “Technical Guidelines on Paper and Paperboard,” which incorporate identical SMLs for MOSH and MOAH, although the limits are still under discussion. The third draft of this Ordinance proposed to set SMLs for MOSH (C 20-C 35): 2 mg/kg of food and MOAH (C 16-C 35): 0.5 mg/kg of food. Notably, the German Federal Ministry for Food and Agriculture (BMEL) had been working on a draft Ordinance on mineral oil saturated hydrocarbons (MOSH) and mineral oil aromatic hydrocarbons (MOAH) for several years now. The migration of mineral oil from food packaging to food has also been under the spotlight. It remains to be seen how Member State BPA laws will be addressed if/when this new EU measure is adopted. The draft sets a specific migration limit (SML) of 0.05 mg/kg for BPA in plastics, varnishes, and coatings based on the EFSA’s 2015 opinion (by contrast to the current SML of 0.6 mg/kg set out in the Plastics Regulation). The current draft outlines that it will apply six months after its entry into force (although an exhaustion of stocks clause would apply). The European Commission is currently working on a draft Regulation on the use BPA in varnishes and coatings intended to come into contact with food and amending the Plastics Regulation (EU) No 10/2011. ![]() Several EU Member States, but most notably France, have national legislation in place prohibiting the placing on the market of certain food contact materials containing bisphenol A (BPA). 10/2011 lists several phthalates as additives, in some cases, their permitted use is very limited and, notably, they are often not authorized for use in packaging for food intended for infants and young children. For example, while the Plastics Regulation (EU) No. However, their use may be strictly regulated under EU or Member State legislation. Many phthalates, including ortho-phthalates, are authorized for use in the manufacture of food-contact materials in the EU. The Danish Veterinary and Food Administration created a fact sheet on fluorinated substances in paper and board for food-contact materials. The Danish Ministry has indicated that although this limit is not legally binding, it will be taken into consideration when assessing whether food-contact paper complies with Article 3 of the EU’s Framework Regulation (EC) No. It is noteworthy that the Danish Ministry of Environment and Food recommended a non-binding migration limit of 0.35 µg fluorine/dm 2 for the total content of organic fluorine in paper. ![]() Indeed, many fluorinated compounds are listed in Member State legislation and in the German Institute for Risk Assessment’s (BfR) paper and paperboard recommendations. In the EU, fluorinated compounds, including perfluoroalkyl ethyl containing food-contact substances, are often used in the manufacture of food-contact materials, notably paper and board. The FDA is to complete its scientific review within 90 days of the filing date of the petition, but the time for the review may be extended by an additional 90 day period.įollowing the FDA’s rejection of certain requests in the April 2016 food additive petition, a citizen petition was filed with the FDA later that same month to remove five ortho-phthalates from the list of prior-sanctioned substances and to prohibit the use of eight other food-contact ortho-phthalates by issuing a new regulation. In April 2016, the FDA also accepted for consideration a food additive petition calling for a revocation of the regulatory clearances for thirty ortho-phthalates when used as components of food-contact articles. ![]() In practice, industry had abandoned the use of these substances years ago. The FDA made its decision based mainly on new data about the toxicity of substances structurally similar to the FCSs, as this new data led to the conclusion that there is no longer a reasonable certainty of no harm for the food contact use of these FCSs. Food and Drug Administration (the FDA) amended the food additive regulations to delist three perfluoroalkyl ethyl containing food-contact substances (FCSs) as oil and water repellants for paper and paperboard for use in contact with aqueous and fatty foods. Starting with the most recent main developments in the U.S., we then briefly look at the current situation in the EU, including ongoing initiatives to tackle some food contact substances that are considered to be of actual or potential concern by the authorities or EU institutions. Nonetheless, in both jurisdictions, there is an increasing focus on specific categories of substances due to potential effects on human health. have traditionally taken a different approach to the regulation of food-contact materials and articles.
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