Food Contact Materials - Regulation (EC) 1935/2004

Good day All.

Trust you are well and keeping safe.

We manufacture moulded fibre products using paper and board (Some parts recycled) used for direct food products such as vegetables and currently certified to BRC Issue 5. Our products have gone through the necessary heavy metals and microbiological testing together with compostability.

Are there any further tests needed to be performed in order to comply to Food Contact Materials - Regulation (EC) 1935/2004?

What tests are needed to be performed to enable us to state, through a declaration, that our products meet Food Contact Materials - Regulation (EC) 1935/2004?

We are based in South Africa.

Thank you in advance.

Paper/board don't have a specific regulation in place at the EU level yet, so it's potentially a little bit of an awkward one in that you have the general requirements of 1935/2004 along with some national regulations/requirements in some countries.

The attached guidance from CEPI Eurokraft might be a useful read for you.

The CEPI document is good but can be scary.

Testing on food contact paper is generally fairly minimal, but knowledge of the supply chain concerning the paper/board is more of a concern. You need to know that the paper is made with materials authorised for food contact and there is guidance on this in the CEPI document. It comes down to asking the right questions of your suppliers.

One area from your post that should be explored is that you use some recycled materials. Knowledge of the sources of these materials is important eg the recyclate must not originate from food processing or health care environments.

Assuming that the raw material data is OK, I would initially limit testing to organoleptic (taint and odour), pentachlorophenol and formaldehyde.

Some customers may ask for additional testing, pesticide sweeps seem to be getting requested more frequently now. 

Thank you this information is helpful.

We currently do know the source of the recycled material and it is not anything from food processing and health care, its primarily overruns.

In terms odour and taint these are addressed through the actual process however will look into the testing that you have mentioned if they can be performed in South Africa.

Dear Bryce23,

because until now still no specific measures exist on EU-level (1935/2004) for paper and board you have to look for national measures.
Within the EU the rule is that any product which is marketable in one member state the product is marketable in the entire EU (in some case with a special hint).

In some cases rules from the council of Europe exits which can be - not legally binding - applied.

-> e.g. for Germany the specific measure to be applied is BfR XXXVI for paper and board.

Is your company the importer into the EU?

Rgds

moskito