European National Legislation

Before the EU started introducing legislation on Food Contact materials, there were multiple sets of legislation around the EU relating to materials in contact with foods. Where the EU have introduced harmonised legislation such as the PIM (EU Regulation 10/2011), national legislations have been repealed. However, there are still quite a number of important classes of Food Contact materials excluded from harmonised legislation and therefore national regulations still apply. These include:

  • Paper and cardboard; covered in Germany by BfR recommendation XXXVI and in the Netherlands by the Warenwet
  • Colourants in plastics; subject to a positive list under French legislation 
  • Rubbers and elastomers; subject to BfR recommendations
European Paper Legislation

Presently, the EU have not introduced any specific legislation relating to paper in contact with foodstuffs - but this does not mean that it is not covered by any legislation. However, paper is still covered by the general safety requirements of the Framework Regulation 1935 (2004) which requires that Food Contact papers should not 'under their normal or forseeable conditions of use, transfer constituents to foodstuffs in quantities which could endanger human health'. 

To demonstrate that this requirement has been met, the most common approaches adopted are to ensure that the material does one of the following;

  • Meets the requirements of national legislation in an EU member state (e.g. the German BfR recommendations or the Dutch Warenwet)
  • Meets the standards set out in the draft Council of Europe resolution on Food Contact papers.

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How we can help:
Smithers Pira can help you devise programmes of compliance against these standards. 
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