Recommendation (EU) 2019/794 informs the industry about an initiative to evaluate food contact materials with regard to their food safety compliance. This will cover a significant number of substances, as well as a large variety of food contact products and materials, some of which have not previously been the focus of similar activities.

SAFEGUARDS | Hardlines NO. 061/19

SafeGuardS fruits in container

Commission Recommendation (EU) 2019/794 on a coordinated control plan with a view to establishing the prevalence of certain substances migrating from materials and articles intended to come into contact with food (FCM) was published in the Official Journal of the European Union on May 17, 2019. This document introduces the strategy to strengthen market surveillance activities for various substances and many types of FCM in the coming months.

A minimum of 1,650 samples shall be evaluated for compliance with FCM safety requirements on substance migration/release, as laid down in Regulation (EC) No 1935/2004, Regulation (EU) No 10/2011 for plastic materials and other applicable legal documents.

The Recommendation (EU) 2019/794 Annex “Actions and Scope of the coordinated control plan” further specifies which requirements are in focus of this market surveillance initiative.

Sample description and methodology:

Substances to be tested Food contact material to be sampled
Primary aromatic amines (PAA) Plastic tableware and kitchenware and printed food contact materials including paper and board
Formaldehyde and Melamine Plastic tableware and kitchenware including non-conventional plastic kitchenware and tableware, such as reusable coffee cups using additives in the plastic derived from natural sources such as bamboo
Phenol Plastic kitchenware and tableware; varnished or coated materials and; printed plastic and paper and board packaging materials
Bisphenols including Bisphenol A (BPA) and Bisphenol S (BPS) Polycarbonate plastic (BPA) and polyethersulfone plastic (BPS); coated metal packaging (e.g. cans, lids)
Phthalates and non-phthalate plasticizers Plastic materials and articles, in particular those manufactured using polyvinylchloride (PVC) such as thermoformed sheets, flexible packaging and tubing; closures and lids
Fluorinated compounds Paper and board based materials and articles, including those used to wrap fast-food, takeaway and bakery products and microwave popcorn bags
Metals Ceramic, enamel, vitreous and metal kitchenware and tableware including artisanal and traditionally produced materials and articles
Overall migration Non-conventional plastic kitchenware and tableware, such as reusable coffee cups using additives in the plastic derived from natural sources such as bamboo

Table 1: Substances and FCM under evaluation

Sample numbers and involved EU Member States:

Member State Recommended minimum total number of samples
Belgium, Germany, Spain, France, Italy, United Kingdom 100
Czechia, Cyprus, Hungary, Netherlands, Poland, Romania 75
Denmark, Ireland, Greece, Croatia, Lithuania, Austria, Portugal, Sweden 50
Bulgaria, Estonia, Latvia, Luxembourg, Malta, Slovenia, Slovakia, Finland 25

Table 2: Involved EU Member States and samples to be taken

The controls should take place from June 1 to December 31, 2019 and the results are to be reported to the Commission by February 29, 2020.

SGS technical experts have extensive knowledge and testing experience in materials and articles in contact with food. They work to ensure that your products meet the appropriate regulations for food contact materials and pave the way for compliance. From overall migration testing to expert advice on emerging regulations and compliance issues as well as documentation reviews, SGS is the partner to trust. Please do not hesitate to contact us for further information or visit our website.

For enquiries, please contact:

Udo Krischke
Global Technical Manager RSTS
t: +49 6128 744 235

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