Is citrus packaging classed as direct or indirect food contact?
Hello,
We are planning to rent a clipnet machine to start packing citrus with it. This means that we need to purchase 3 new packaging materials: the net, the small metal piece to close the net and a label which will be attached to the metal. It is obviouse for everyone that the net has direct contact with the fruit, but what do you consider of the other 2 componets of the packaging (the metal piece and the label). Although they are not initially intended to come in direct contact with the product, I still see that they might incidently come in contact with it, depending on how the label and metal might rest on the product. My intention is to ask food contact declarations of compliance for all 3 elements, but I'm already getting affraid of the reaction that I will receive. A lot of packaging material manufacturiers, especially for articles that we would put to the category "various", have no idea of what I'm asking from them.
I attached a picture found on internet to make it more clear what I'm saying. picture clipneted oranges.jpg 176.84KB 0 downloads
Hi ilonadlb,
I think you are correct that you have to treat these as potentially food-contact.
Article 1(1) of Regulation (EC) 1935/2004 states: "The purpose of this regulation is to ensure the effective functioning of the internal market in relation to the placing on the market in the Community of material and articles intended to come into contact directly or indirectly with food, whilst providing the basis for securing a high level of protection of human health and the interests of consumers."
And article 1(2)© states: "This regulation shall apply to materials and articles, including active and intelligent food contact materials and articles (hereinafter referred to as materials and articles) which in their finished state... can reasonably be expected to be brought into contact with food or to transfer their constituents to food under normal or foreseeable conditions of use".
Given that you'll presumably be selling/shipping these in cardboard cases or similar where the labels will almost certainly be pressed against the nets/fruit, I'd very much think that the above applies.
The net yes, the metal piece and the label no.