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Composite materials containing bamboo and melamine-formaldehyde resin are facing scrutiny in the EU. Recent risk assessments by the German Federal Institute of Risk Assessment (BfR) and European Food Safety Authority (EFSA) reconfirm specific migration issues and use of questionable additives.

SAFEGUARDS | Consumer ProductsNO. 181/19

 SG 18119 Bamboo Culteries

In SafeGuardS No. 108/19, we informed you about market surveillance activities and concerns relating to bamboo-containing food contact materials and articles with melamine-formaldehyde resin as the structural/shaping matrix – the so called ‘bambooware’.

On November 25, 2019 BfR issued a risk assessment study on the use of food contact materials and articles made from melamine-formaldehyde resin with and without plant-based filler additives. These resins are often combined with bamboo fibers (or other plant-based additives) to manufacture reusable coffee to-go cups, tableware or other food contact products. The study indicates that, from a food safety perspective, these items are not necessarily suitable for use as reusable food contact products as melamine and formaldehyde were found to migrate from these materials into food at high temperatures. In addition to BfR’s own studies, these findings were also revealed by other German federal state market surveillance agencies. In many cases, higher quantities of formaldehyde and melamine were released from bambooware than from ‘conventional’ melamine resin items. On average, the specific migration values were found to be up to 30% higher for formaldehyde and 100% higher for melamine.

The test data included specific migration of formaldehyde from 366 cups and bowls as well as specific migration of melamine from 291 products. Compared to tolerable daily intake limits (TDIs) set by EFSA, BfR found that  for about 25% of all bambooware these values were exceeded for formaldehyde by up to 30 times for adults and by up to 120 times for children. For melamine migration, adults were found to be safe. However, infants who often consume hot food/drinks from this type of tableware were found to potentially absorb TDI for melamine up to three times the TDI. The BfR concluded that there was a possible increase in health risk for consumers drinking hot liquid foods from melamine-type tableware. For bambooware, a possible reason for the increase in health risk was due to high levels of formaldehyde migration from long-term daily use of such items.

Repeated use simulation tests on the same specimen, using 3% acetic acid at 70°C for 2 hours, also indicated an increasing level of melamine migration. BfR states that this indicates the material deteriorates when in contact with hot liquids and concludes that melamine-formaldehyde resin is generally not suitable for repeated use articles in contact with hot liquid foods. The BfR advises consumers that melamine-containing tableware should not be used in microwaves. As a consequence, the BfR recommends lowering the specific migration limit for formaldehyde from the present 15 mg/kg to 6 mg/kg in Commission Regulation (EU) No 10/2011.

Another risk assessment related to the use of plant-based additives in plastic food contact materials and articles (FCMs) was published on November 29, 2019 in the EFSA Journal, Opinion 5902. The EFSA was asked by the European Commission to review whether the authorization of ‘wood flour and fibers, untreated’ (Entry No 96 in Regulation (EU) No 10/2011) is still in accordance with Commission Regulation (EC) No 1935/2004. The additive was included in the list of additives for use in plastic FCMs based on the assumption of its inertness. However, no toxicological evaluation supporting the inclusion of wood in the positive list is available. Wood may contain toxic components and contaminants and the information on migration of such substances from wood into foodstuffs is very limited. Substance migration data from the use of wood as a plastic additive was not available. The EFSA concluded that there is insufficient information to support the current authorization of ‘wood flour and fibers, untreated’ as in accordance with Regulation (EC) No 1935/2004. 

The EFSA also sets out criteria for future evaluations of wood and similar materials from plant origin as plastic additives for food contact applications. The safety of migrating substances from these materials must be evaluated on a case-by-case basis due to differences in chemical composition of plant materials. The considerations are beyond species and would also include origin, processing, treatment for compatibility with the structural shaping components of plastics and assessment of low molecular weight constituents migrating into food. Comparative testing in samples manufactured with or without additives should be made on the migration of substances from the use of wood or other plant materials as additives. Toxicological data should cover the substances detected coming from such tests.

In conclusion, from these recent risk assessments, it is likely that food contact composite materials containing bamboo (or other plant) powder and melamine-formaldehyde resin will continue to face scrutiny in the EU market.

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 test to expert advices on emerging regulations and compliance issues and documentation review, SGS is the partner to trust. Please do not hesitate to contact us for further information or visit our website.

For enquiries, please contact:

Dr. Udo Krischke
Global Technical Manager RSTS
T: +49 6128 744 235

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