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France Proposes Mineral Oil Requirements under Anti-Waste and Circular Economy Law

SafeGuardSFood Contact MaterialFebruary 28, 2022

France is proposing to regulate two categories of mineral oil in ink on packaging and printed matter of paper. Their restrictions would be implemented in two phases, starting January 1, 2023.

On February 10, 2020, France published Decree No. 2020-105 on the ‘Fight Against Waste and the Circular Economy’. Article 112 to this law regulates the use of mineral oils on packaging. It: 

  • Prohibits mineral oils on packaging from January 1, 2022
  • Prohibits mineral oils for printing intended for the general public from January 1, 2025. This prohibition, however, will become effective on January 1, 2023 for unsolicited advertising materials and catalogues for commercial promotions
  • Allows the applicable conditions of Article 112 to be defined by Decree.

According to Articles D543-45-1 and D543-213 of the Environment Code and Decree No. 2020-1725 of December 29,2020 ‘Various Adaption Provisions Relating to Extended Producer Responsibility’ (the Law), the conditions for the implementation apply to mineral oils containing substances that disrupt the recycling of packaging waste paper or restrict the use of recycled materials because of the risk of these substances to human health.    

On February 3, 2022, the World Trade Organization (WTO) announced a draft Decree from France’s Ministry for Ecological Transition (Ministère de la Transition écologique) on its intention to regulate two categories of mineral oil and their requirements for the implementation of Articles D543-45-1 and D543-213, as well as Decree No. 2020-1725. The draft Decree, attached to WTO document number 22-0811, and notified under G/TBT/N/FRA/2016, contains several important provisions, it:

  • Pushes back the date of entry into force of Article 112 to Decree No. 2020-105 from January 1, 2022 to January 1, 2023
  • Defines mineral oils as oils produced from feedstocks derived from petroleum hydrocarbons used in the manufacture of inks
  • Defines mineral oils as mineral oil aromatic hydrocarbons (MOAH) consisting of 1 to 7 aromatic cycles and mineral oil saturated hydrocarbons (MOSH) consisting of 16 to 35 carbon atoms
  • Specifies requirements for MOAH and MOSH in ink:
    • ≤ 0.1% MOAH (≤ 1 ppb MOAH compounds consisting of 3 to 7 aromatic cycles from January 1, 2025)
    • ≤ 1% MOSH (≤  0.1% MOSH from January 1, 2025) 

There are two transitional periods:

  • Packaging and printed matter of paper manufactured or imported before January 1, 2023, are required to be disposed by December 31, 2023
  • Compliant packaging and printed matter of paper manufactured or imported before each of the deadlines in the aforementioned point 4 are required to be disposed of within 12 months from those deadlines 

According to the WTO document, it is proposed that the draft Decree is:

  • Adopted on June 30, 2022
  • Brought into force on January 1, 2023

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