Food Contact Legislation & other topical issues related to Metal Packaging

Campden BRI – a short history

1914 – Committee looking at preservation of fruit & vegetables by drying, canning and other means

1919 - Campden Experimental Factory 1921 - Univ. of Bristol Fruit & Vegetable Research Station

(Campden Research Station)

1952 - Fruit & Vegetable Canning & Quick Freezing RA 1966 - Fruit & Vegetable Preservation Research Assoc. 1972 - Campden Food Preservation RA 1988 - Campden Food & Drink RA 1995 - Campden & Chorleywood Food RA

2008 - Campden BRI

Chipping Campden

Nutfield

Hungary

Campden BRI

•  Membership based c.2050 members •  Independent, Non-profit distributing •  International – clients in 70 countries •  Turnover: c. £21 m •  Staff: 390 •  Industry and Government Clients

•  Member involvement and influence - Governance - Scientific & Technical Strategy - Project development & selection

•  Largest independent in the world

EU Legislation •  EU framework Regulation on food contact

materials

•  Good Manufacturing Practice

•  Specific EU rules on food contact materials –  Plastics –  Recycled plastics –  Regenerated cellulose film –  Vinyl chloride monomer, nitrosamines, epoxy

derivatives –  Active and intelligent materials and articles (AIM) –  Ceramics

The Framework Regulation

•  Commission Regulation (EC) No. 1935/2004 on Materials and Articles Intended to come into Contact with Food (as amended).

Scope The Regulation applies to materials and articles which

are: •  Intended to be brought into contact with food or

•  Are already in contact with food and were intended for that purpose or

•  Can reasonably be expected to come into contact with food or transfer their constituents

E.g. packaging, cutlery, work surfaces, processing machinery.

General Requirements Article 3

•  Contact materials should not transfer constituents to food in quantities which could endanger health or adversely affect the composition or organoleptic [sensory] qualities of the food

•  Labelling, advertising and presentation of a material or article shall not mislead

Specific Measures The Regulation also establishes 17 groups of materials and articles which may be covered by specific measures:

Active and intelligent materials/articles* Adhesives Printing inks Ceramics* Regenerated cellulose* Cork Rubber Glass Silicones Ion-exchange resins Textiles Metals and alloys Varnishes and coatings Paper and board Waxes Plastics* Wood.

Other Key Provisions: Traceability

•  Mirrors the general traceability requirement for food producers, packaging needs to be treated as another ingredient for traceability purposes

•  Traceability applies at all stages of manufacture, processing or distribution

•  ‘One forward and one back’ principle

•  Information to be available to authorities on demand.

Other Key Provisions

•  Declarations of compliance – for materials covered by specific measures; also recommended by FSA as good business practice for others

•  Substance authorisation – procedure for materials covered by specific measures

•  Safeguard measures – where a Member State has evidence of a food safety issue with an EU-compliant material

Good Manufacturing Practice

•  Commission Regulation (EC) No. 2023/2006

•  GMP: those aspects of quality assurance ensuring conformity with rules and appropriate quality standards on not jeopardising food safety or otherwise adversely affecting the food

•  Combination of general and detailed rules.

Good Manufacturing Practice

•  General rules

–  Documented quality assurance system taking account of personnel, premises, equipment, size of business, specifications for raw materials

–  Quality control system involving monitoring GMP and identifying measures to correct any failure

–  Documentation on specifications and operations, available to Local Authorities on request.

Good Manufacturing Practice •  Detailed rules – very brief

– Printing inks •  Components in printing inks must not transfer to the

food-contact side either through the packaging or by set-off such that amounts in the food are unacceptable

•  Printed surfaces must not come into direct contact with food

– Quality assurance system for plastic recycling processes

•  Must ensure compliance with the authorisation and be documented via written policy statements and procedures

Tin in canned Foodstuffs

(EC) No 1881/2006 Commission Regulation of 19 December 2006

setting maximum levels for certain contaminants in foodstuffs

Permitted levels of tin in food Foodstuffs Maximum levels

(mg/kg wet weight) Canned foods other than beverages 200 Canned beverages, including fruit juices and vegetable juices 100

Canned baby foods and processed cereal-based foods for infants and young children, excluding dried and powdered products

50

Canned infant formulae and follow-on formulae (including infant milk and follow-on milk), excluding dried and powdered products

50

Canned dietary foods for special medical purposes intended specifically for infants, excluding dried and powdered products

50

Commission Regulation (EC) No. 1895/2005 on certain epoxy derivatives

•  BFDGE and NOGE banned from use •  BADGE has SML of 9mg/kg

BPA - EU

BPA banned in baby feeding bottles Permitted in all other applications EU Plastics Regulation (10/2011) has a SML of 0.6mg/kg

Migration of BPA from coatings is well below the established specific migration limit in Plastics Regulation of 0.6mg/kg food

BPA Regulation – EU & Member States France - Decree enter into force on 1 October 2013 –

covers “Packaging made using bisphenol A. Use not recommended for pregnant or breast- feeding women or for children under 3”.

Belgium - Ban on BPA in food packaging for 0-3 years from 1st Jan 2013 voted in but on hold

Sweden - Ban on BPA in food packaging for 0-3 years from 1st Jan 2013 voted in but on hold

Denmark - Ban on BPA in food packaging for 0-3 years in place

Austria - Ban in place on “sippy cups” and soothers

FDA’s Current Perspective on BPA

•  FDA’s current assessment is that BPA is safe at the very low levels that occur in some foods.

•  This assessment is based on review by FDA scientists of hundreds of studies including the latest findings from new studies initiated by the agency

•  FDA is not recommending that families change the use of infant formula or foods, as the benefit of a stable source of good nutrition outweighs the potential risk from BPA exposure

Council of Europe - Metal •  Draft of the main resolution is understood to

be complete. Awaiting release of final texts. •  The SRLs fixed for

–  iron (40mg/kg) and – aluminium (5mg/kg).

•  Acid simulant testing of open metal packaging not appropriate.

Coatings – internal food contact

•  Plastics Regulation (EC) 10/2011

•  Framework Resolution Resap(2004)1 on Coatings intended to come into contact with foodstuffs

Current issues

•  External Corrosion – low tin weight •  Internal – nitrite in product leading to

detinning

Potential projects

•  Understanding reactions of new BPA-NI coatings with food products - Product effect leading to coating failure

•  Guidelines on causes & possible controls related to external corrosion of metal cans

Thank You Any Questions? Alan Campbell Alan.campbell@campdenbri.co.uk +44 (0)1386 842081