Food contact materials

Food contact materials are defined as all kind of materials that can be in contact with food. These can be things that are quite obvious like a glass, a can for soft drinks, but also machinery in a food factory or a coffee machine.

Food contact materials can be constructed from a variety of materials like plastics, rubber, paper, coatings, metal etc. In many cases a combination is used; for example a carton box for juices can include (from the inside to the outside): plastic layer, aluminium, paper, printing and top coating.

During the contact of the food contact materials with the food, molecules can migrate from the food contact material to the food. Because of this, in many countries regulations are made to ensure

EU legislation

A few decades ago, the EU has started with the harmonization of the legislation on food contact materials. At this moment only for a few materials a legislation does exist. Legislation for the ceramics and regenerated cellulose can be considered as complete, while the legislation on plastics, rubber, coatings and adhesives in the building phase.

Two types of legislations can be distinguished:

Directives, which should be implemented in the national legislation, before becoming into force andRegulations, which will be in force immediately and may not be implemented in the national legislation One important Regulation is the framework Regulation (EC) No. 1935/2004. This regulation does apply to all food contact materials and has some definitions, restrictions and requirements:

Article 3 Does contain general safety requirements like:Not endanger human health No unacceptable change in the composition No deterioration of the organoleptic characteristics Article 4 Active and Intelligent materials may be used if… Article 6 Member states may maintain or adopt national provisions. These are summarized in the "National Legislation" on the left frame by country and in the "materials" on the left frame summarized by type of material. Article 15 About labeling of food contact materials not yet in contact with food and the symbol which may be used to identify food contact materials. Article 16 Declaration of compliance and appropriate documentation that demonstrate compliance must be made available on demand of authorities Article 17 Traceability

Beside these EU regulation legislation may exist on national level. more information can be found at [http://www.foodcontactmaterials.com legislation on food contact materials]

Introduction to FDA legislation

It is very difficult to present a complete introduction of the FDA legislation and the practical use for the clearance of a food contact material. This page must be considered as a short introduction to get familiar with the vocabulary. If you are not experienced with handling the FDA regulations, please be careful to avoid misinterpretations.

The FDA considers three different types of food additives:- Direct food additives Components added directly to the food - Secondary direct food additives Components that are added to the food due to food treatment like treating food with ionic resins, solvent extraction - Indirect food additives Substances that may come into contact with food as part of packaging or processing equipment, but are not intended to be added directly to food

The food contact materials are described in the Code of Federal Legislation (CFR): 21 CFR 174 - 21 CFR 190. Important starting points are: 21 CFR 175 Indirect food additives: Adhesives and components of coatings 21 CFR 176 Indirect food additives: Paper and paperboard components 21 CFR 177 Indirect food additives: Polymers

To this materials additives may be added. Which additives depend on the additive and on the material in which it is intended to be used. There must be a reference to the paragraph in which the additive is mentioned and the restrictions (for example only to be used in polyolefines) and limitations (max 0.5% in the final product) must be respected. See below for part in which additives are described: 21 CFR 170 Food additives 21 CFR 171 Food additive petitions 21 CFR 172 Food additives permitted for direct addition to food for human consumption 21 CFR 173 Secondary direct food additives permitted in food for human consumption 21 CFR 178 Indirect food additives: Adjuvants, production aids, and sanitizers 21 CFR 180 Food additives permitted in food or in contact with food on an interim basis pending additional study

Polymers or additives can also be regulation in other ways, the exemptions, like:- Threshold of regulation - Food contact notification - Private letters - Prior sanctioned food ingredient - Gras