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Systematic derivation of Correction Factors (CFs) to relate chemical migration levels from paper and board into foods
Food contact applications represent an important part of the paper and board packaging sector.
CEPI’s activity in this field aims at ensuring that this sector can continue to supply its products in a market that is increasingly controlled by regulation, food scares and customer demands. CEPI’s view is to protect businesses, while increasing consumer safety.
In the EU, food contact materials and articles shall comply with the framework Regulation 1935/04.More specifically, the Regulation’s main principle is that they should not “transfer their constituents to food in quantities which could endanger human health or bring about an unacceptable change in the composition or a deterioration of the organoleptic characteristics of the foods”.
Therefore, the focus is on the transfer of constituents, verified via the so-called “migration tests”.
These tests imply the use of food simulants that mimic the behaviour of a certain food (or a class of foods) with respect to its capability to absorb the substances that may be transferred (may migrate) from the packaging.
In many cases, the real behaviour of a material/article may be over- or under-estimated by carrying out tests with the use of simulants. Consequently, Correction Factors should be used so that the migration test results are aligned with the real situation and to ensure that the safety assessment is precise.
In other words, Correction Factors aim at relating migration levels into food with migration levels obtained with the food simulants or extraction solvents used in simplified and standardised test procedures. The use of Correction Factors is envisaged in the EU legislation.
CEPI, with DG Sanco’s guidance, funded a research work on Correction Factors carried out by Laurence Castle, a well-known and estimated scientist, active in the field of food contact materials since many years. Laurence works at FERA, the UK Food and Environment Research Agency.
The report includes a review of published research works along with any unpublished reports on the topic of Correction Factors provided for this review by CEPI. The aim was to relate chemical migration levels from paper and board into foods, with the migration or extraction values obtained using food simulants or solvents, as well as to propose a set of Correction Factors, where justified. The CEPI Food Contact Group has given its support to this work by providing comments in the report’s review phase.
The set of information contained in this work will be one of the tools to be used in the discussion with EU authorities on a specific, EU-harmonised regulation on paper and board for food contact that CEPI is currently advocating for.
Darmstadt University analysis: packaging is not responsible for mineral oils found in chocolate from advent calendars
The German consumer organisation Stiftung Warentest published test results according to which most chocolates in 24 tested advent calendars in Germany contained mineral oil hydrocarbon residues. Stiftung Warentest also mentioned recycled cardboard packaging as the source of those residues. An analysis of the Technical University Darmstadt published today, shows that this conclusion is not appropriate.
The Paper Technology and Mechanical Process Engineering Unit of the Technical University in Darmstadt obtained each of the 24 calendars tested by Stiftung Warentest to conduct an analysis on the fibre content of the calendars. This is a standard test that Darmstadt University conducts on a regular basis. The results show clearly that 23 out of the 24 calendars tested are made of virgin fibre, only one contained recycled fibre.
The broad statement from Stiftung Warentest that mineral oil hydrocarbons in the chocolate of their tested advent calendars originates most likely from the recycled cardboard packaging is questionable and cannot be correct. The source is not the cardboard used in the calendars.
There are several possibilities of how mineral oils can get into chocolate. The root cause for this still needs to be determined. As potential sources Darmstadt University listed additives and processing chemicals used during food production and other packaging materials (e.g. plastic trays) as well as potential contamination during transportation and storage.
As a precautionary measure the paper-based fibre chain has implemented several voluntary actions on this issue, taking a pro-active and innovative action to solve the case. The industry has also developed self-regulation: Industry Guideline for Food Contact Materials and a guidance on GMP (Good Manufacturing Practise) to ensure a consistent European production of safe food packaging.
Note to the Editor
For more information, please contact: Eugenio Cavallini, CEPI Technical Manager, at firstname.lastname@example.org / tel. +32 2 627 49 25 or Jori Ringman-Beck, CEPI Recycling, Product & Environment Director, at email@example.com / tel. +32 2 627 49 19.
Industry Guideline: http://www.cepi.org/topics/foodcontact/publications/Industryguidelineissue2
Stiftung Warentest: http://www.test.de/Adventskalender-mit-Schokoladenfuellung-Mineraloel-in-der-Schokolade-4471436-0/
BfR: http://www.bfr.bund.de/de/presseinformation/2012/41/mineraloele_in_schokolade_und_anderen_lebensmitteln_sind_unerwuenscht-132174.html (German)
The German Environment Protection Agency, Umweltbundesamt: http://www.umweltbundesamt.de/uba-info-presse/2012/pd12-047_mineraloelrueckstaende_in_adventskalendern_sind_vermeidbar.htm
CEPI, the Confederation of European Paper Industries, and CITPA, the Confederation of Paper and Board Converters in Europe, have revised their Industry Guideline for the compliance of paper and board materials and articles for food contact.
The purpose of the Industry Guideline is, in the absence of a specific measure for paper and board, to enable manufacturers of paper and board materials and articles intended for food contact to demonstrate compliance with the Framework Regulation, (EC) No 1935/2004. The Guideline is however offered only as voluntary guidance for operators in the industry and there is no intention to replace existing national legislation, which will always take precedence.
Paper manufacturing companies, representing around 50% of the European production of packaging grades, and 20 major converting companies covering a large share of the European paper-based packaging production implemented the Industry Guideline during 2010, the first year of its publication. Many other papermakers and converters are in the process of adopting it in their operations. A further survey of the continuing uptake of the Guideline is foreseen in the coming months following the publication of this revised version. When the Industry Guideline was conceived, relatively frequent revisions were foreseen to take account of developments. The specific aspects covered in this first revision are:
- the publication of the new CEPI Good Manufacturing Practice (GMP)
- the coming into force of Commission Regulation on plastic materials and articles
intended to come into contact with food, (EC) No 10/2011)
- the update of German Recommendation on paper and board for food contact (BfR
Rec. XXXVI) ,and
- the concerns over the presence of mineral oil hydrocarbons in food
The revision has been made by the same process as the first issue through the work of a Cross Industry Group. The Group will continue its monitoring activity of the sector and the collection of inputs to be taken into account for further revisions. “The paper and board industry has envisaged its Guideline as a moving document which needs to be updated. This is the challenge we have adopted within the industry, supplying safe products and demonstrating compliance with relevant legislation”, said John Swift, Chair of the Cross Industry Group responsible for drafting the Industry Guideline.
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Industry guideline for the Compliance of Paper & Board Materials and Articles for Food Contact: Issue 2 EN/DE/ES/IT/PL/NL
The Industry Guideline for the Compliance of Paper & Board Materials and Articles for Food Contact was first published by CEPI and CITPA two years ago.
It has been well received by organizations and authorities at both European and national level, and has become a reference for the paper and board food packaging value chain. Its uptake has been wide and the greater part of the text is still considered to be current.
The Industry Guideline was however conceived as a moving document, aligned with the whole food contact material sector, which is continuously evolving. Fairly frequent revisions were therefore envisaged and this new version is considered timely.
Stakeholders in the Industry Guideline were surveyed to assess the revision needs and from this survey a list of aspects to be revised was compiled. Key amongst these aspects were:
• the publication of the new CEPI GMP
• the coming into force of Commission Regulation (EU) No 10/2011 for plastics
• the update of the German BfR Recommendation XXXVI, and
• the concerns over the presence of mineral oils hydrocarbons in food
The revision has been made through the work of a Cross Industry Group, thus reflecting and continuing the original cross industry approach.
The Cross Industry Group will continue its monitoring activity of the sector and the collection of inputs to be taken into account for the next revision.
The underlying aim is to make available to all stakeholders a relevant tool for demonstrating compliance of paper and board packaging and for the continuing supply of safe products to consumers
This publication has been translated into German, Italian, Spanish, Polish and Dutch.