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Denmark has completed a consultation on its draft Ordinance on, among other things, the prohibition of PFAS chemicals in food contact paper and paperboard materials and articles. The provisions are proposed to become effective on July 1, 2020.

SAFEGUARDS | Hardgoods NO. 143/19

Food contact paper

On September 2, 2019, the Danish Ministry of Environment and Food announced its intention to ban on perfluoroalkyl and polyfluoroalkyl substances (PFAS, also known as PFAS chemicals) in food contact paper and paperboard materials and articles.

According to the announcement, paper and paperboard materials can be treated with PFAS chemicals to give anti-grease and water properties. These materials can be used in the fast food industry and other food contact items.

On the same day as the announcement, the Danish Veterinary and Food Administration launched a public consultation over its draft Ordinance on food contact materials and penalties for violation of EU-related legislation. The consultation, which ended on September 22, 2019, received a number of responses.

The draft Ordinance would repeal Ordinance No. 1248 of October 30, 2018, on food contact materials and articles. It contains, inter alia, several important changes:

  • Addition of a definition for paper and paperboard
  • Inclusion of a ban on PFAS chemicals in food contact paper and paperboard materials – they are allowed if there is a functional barrier in the product to avoid migration into food
  • Inclusion of a transitional provision for food contact paper and paperboard materials and articles that are placed on the market before the effective date

According to the definition in the draft Ordinance, paper and paperboard means materials and articles made of cellulose-based natural fibers from virgin and recycled sources. They can contain artificial fibers, functional additives and other agents, binders, plastic films, ink, varnishes, coatings and glue.

Highlights of the draft Ordinance on PFAS chemicals in food contact paper and paperboard materials are summarized in Table 1.

Draft Ordinance on Food Contact Materials and the Penal Code for Violation of Related EU Legislation
Substance Scope Requirement Effective Date
PFAS chemicals Food contact paper and paperboard materials and articles Prohibited* July 1, 2020**

* PFAS chemicals may be used in food contact paper and paperboard materials and articles provided a functional barrier is in the product to prevent the migration of substances into food

** Food contact paper and paperboard materials and articles meeting the general requirements in Regulation (EC) 1935/2004 and placed on the market before July 1, 2020, may remain on the market until stocks are exhausted

Table 1.

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