Global food contact regulation updates for 3 rd quarter 2023

Abstract

Government agencies around the world regulate food contact materials or articles. Understanding these regulations and keeping up with the new regulations are essential for maintaining market access for food contact products. My intent is to provide global plastics food contact regulation developments and updates relevant to plastic film and sheet for food packaging.

Keywords

Food contact Food Packaging Compostable Recycling Prop 65 MOSH MOAH BPA

Country

China

The China National Center for Food Safety Risk Assessment (CFSA) published a draft¹ (in Chinese) amendment to the GB 4806.1–2016, General Safety Requirements for Food Contact Materials and Articles. The proposed major changes include the introduction of “complete barrier” concept; food raw materials are allowed to be used as food contact materials although “food raw material’ is not clearly defined; additional compliance labeling requirements; and requirements for the Declaration of Compliance document.

USA

Two bills from 2022 are re-introduced in the US Congress this year. Bill S1189,² Recycling Infrastructure and Accessibility Act of 2023, proposes to establish a pilot grant program for funding recycling infrastructure, aiming to improve recycling accessibility in a community or communities within the same geographic area. Bill S1194,³ Recycling and Composting Accountability Act, requires EPA to carry out certain activities to improve recycling and composting programs in the US, including identify challenges, improve data collection, assess end markets, and establish voluntary best practices with respect to recycling and composting.

Several US States enacted Compostable Labeling laws, for example: California AB1201,⁴ Colorado SB253,⁵ Maryland HB1349,⁶ Minnesota HF2310,⁷ and Washington HB1799.⁸ These states laws specify requirements for “Compostable” labeling for product and packaging including criteria, label requirements, and requirements for third party certification bodies.

California Office of Environmental Health Hazard Assessment (OEHHA) proposed⁹ lowering the “No Significant Risk Level” (NSRL) for ethylene oxide, listed in Prop 65, from 2 μg (μg) per day to 0.058 μg (μg) per day. Ethylene oxide may be an impurity in certain polymer and Post-Consumer Recycled plastics. If OEHHA succeeded in lowing the NSRL for ethylene oxide, it would create a challenge in analytical testing for ethylene oxide.

Region

EU

European Food Safety Authority (EFSA) published its draft scientific opinion on the risk assessment of mineral oil hydrocarbons in food for public consultation.¹⁰ The focus of the opinion is on the safety of mineral oil saturated hydrocarbons (MOSH) and mineral oil aromatic hydrocarbons (MOAH). EFSA experts provisionally concluded that MOSH do not pose a health concern. They also confirmed that some substances in the group known as mineral oil aromatic hydrocarbons (MOAH) are a possible health concern. Certain grades of mineral oils are approved for use in food contact materials. It is also used in printing inks of food packages.

In a recent re-evaluation of bisphenol A (BPA), EFSA experts have concluded that dietary exposure to BPA is a health concern for consumers across all age groups.¹¹ Based on all the new scientific evidence assessed, EFSA’s experts established a Tolerable Daily Intake (TDI) of 0.2 ng (0.2 billionths of a gram) per kilogram of body weight per day, replacing the previous temporary level of 4 μg (4 millionths of a gram) per kilogram of body weight per day. The TDI is around 20,000 times lower than before.

Footnotes

Notes

Biography

Huqiu Zhang holds a PhD in organic chemistry and is currently a Principal at Sevee and Maher Engineers, a consulting firm. She provides technical consultation for product chemical safety and global regulatory compliance to clients in food contact material (including virgin and Post-Consumer recycled materials), food packaging and consumer product industries. Her expertise includes regulatory compliance strategies, implementation, and government agencies pre-market clearance and approval for new food contact materials; supply chain chemical management program and Good Manufacturing Practice (GMP); business Due Diligence, chemical hazard identification, exposure evaluation and risk assessment. She played a critical role in opening a communication channel between the US FDA and China MOH agencies. She built relationship and establishing project collaboration between the US SPI and China MOH agency in the areas of food contact material safety and regulations. Her working experiences extends to the whole supply chain of food packaging and consumer product, with chemical industry (BASF/Ciba Specialty Chemical); material and compounding industry (GE Plastics); food/beverage industry (The Coca Cola Company); Testing, Inspection and Certification Industries (Intertek). Huqiu is on the Board of Technical Adviser for Zymtronix, a multi-scale platform technology startup that revolutionizes the use of enzymes and leads the next wave of improvements in Green Chemistry and Biocatalysis. She has spoken at numerous international conferences in her areas of expertise.