Q. What effect does this new regulations have?
A. The changes brought about by EU Regulation 37/2019 are relatively minor and mostly focus on bringing the positive list up to date with the most recent risk assessments from EFSA. Three new substances have been added to the positive lists of substances approved for use in food contact plastics and changed use restrictions on a further 4 substances. Additionally, there have been some minor clarifications in relation to the selection of food simulants for use in migration testing. Given that there are now circa 1060 substances on the positive lists, it is certain that most users and producers of food contact materials probably won’t be significantly impacted by the changes on these few substances. But there will be a small percentage who are affected.
Q. Where can we see a copy of this new Regulation?
The new regulation can be downloaded from the European Commission website.
Q. So what should producers and users of food contact materials do to respond to these changes?
The first and most obvious action would be to check through the list of substances in your food contact materials to ensure that none of these have been impacted by the recent changes. If you don’t have access to the full list of substances in the plastics, you may need to ask your suppliers for an up-to-date Declaration of Compliance which covers these amendments. In carrying out this review, you may need to consider that with the recent increased frequency of amendments to the legislation, many suppliers of plastics will not yet have brought their declarations of compliance fully up-to-date. If you need any help in reviewing the status of materials, please feel free to contact us to discuss.