Article | REF: M4490 V2

Food contact materials - Regulations

Author: Albert KOZLOWSKI

Publication date: March 10, 2011

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ABSTRACT

The producers of materials intended for contact with food stuffs are obliged to manufacture a product that must be suitable and effective for the intended purpose of use and ensure the sanitary safety of the consumer. To achieve this, suppliers and users of the food chain are expected to apply French and European regulations. Indeed, the regulations define the principle of inertia of the material and its control, as well as respecting the selection of raw materials. Accordingly, a ban has been placed to prohibit the placement of non-compliant materials on the market, or food stuff that has been in contact with non-compliant materials. However, the current French regulatory and normative situation is still fragmentary and the European situation that is not yet satisfactorily defined often renders the selection of these materials complicated.

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AUTHOR

 INTRODUCTION

European regulations on the safety of materials and articles in contact with foodstuffs are the responsibility of DG-Sanco (Directorate-General for Health and Consumer Protection) within the European Commission. It mainly covers two recent provisions described in the rest of this article:

  • regulation no. 178/2002 of January 28, 2002 ;

  • framework regulation (EC) no. 1935/2004.

The scope of the regulations is divided into :

  • intended for contact with food materials and objects;

  • in contact with foodstuffs.

These distinct concepts give responsibility to two main types of operator:

  • suppliers, involved in the materials and objects chain (manufacturing, processing, distribution, marketing). At this stage, materials and objects are intended to come into contact with food;

  • users, who are involved in the food chain (production and distribution of foodstuffs) and who are either direct users or distributors. At this stage, materials and objects are brought into contact with foodstuffs.

Consequently, for these operators, it is forbidden to market :

  • materials and objects intended to come into contact with food that do not comply with regulations;

  • foodstuffs that have been brought into contact with materials and objects declared to be non-compliant with regulations.

Manufacturers of materials and articles intended to come into contact with foodstuffs are required to produce a product that is suitable for use and safe for the consumer. To this end, the manufacturers concerned refer in particular to French (grouped together in brochure 1227 published by the Direction des journaux officiels) and European regulatory texts which define the principle of material inertia and its control, as well as compliance with the choice of raw materials from a positive list corresponding to the type of material.

In the field of metallic materials, apart from the general principle of inertia, French regulations are still fragmentary, and European regulations have not yet been drawn up.

The aim of the articles on the "alimentarity of materials" is to take stock of the current normative and regulatory situation through the labyrinth of texts, in order to choose materials suitable for contact with foodstuffs. This series comprises three articles:

  • this one dedicated to Regulations;

  • ...
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