Frequently asked questions about contact materials

On these web pages you will find the common questions asked by the Ruokavirasto (Finnish Food Authority) with their answers. The question-and-answer pairs are listed by subject. Because many things may belong to more than one topic, you may want to look at several points if you do not immediately find the answer on the first topic page.

This first page contains general questions about food contact materials.

 

Are serviettes, tablecloths, kitchen roll and kitchen scissors food contact materials?

Yes, they are.

Are oven gloves and mitts made of fabric interpreted as being food contact materials?

Generally, all kitchenware has been interpreted as being contact material, but based on current interpretation oven gloves and mitts have not.

Are the utensils and appliances used in food preparation food contact materials?

Yes, they are. Also, the materials used to repair such appliances (e.g. materials used for patching or welding) are contact materials and must comply with the requirements set out for contact materials.

Is the machinery and equipment used in the manufacture of food packaging materials considered as being food contact materials?

No, these are not food contact materials.

What are the requirements of the law for food packaging and containers?

According to EU’s framework regulation 1935/2004, the main requirement is that a material or article coming into contact with food (so called contact materials) may not, under usual or expected usage conditions, release such quantities of substances into food that they might

  • endanger human health
  • bring about an unacceptable change in the composition of the food o
  • deteriorate the food’s sensory properties.

In addition to food packaging and tableware, this requirement applies to all other devices and utensils that are directly or indirectly in contact with food during the manufacturing process.

Do contact materials require some kind of separate approval by an authorised  research institution or how is a material/product verified as being approved as a contact material?

There is no formal authorisation procedure for contact materials. On the other hand, authorisation has been given for the constituents from which some materials (plastic and regenerated cellulose, constituents used in active and intelligent materials) may be made. A manufacturer who knows the composition of the contact material and has examined its suitability for food contact is obliged to provide the customer with so-called compliance documentation attesting chemical suitability for food contact, the justification for this (e.g. legislation, examinations, etc.) as well as instructions for use (at least food types, temperature limits and contact time restrictions). The requirement comes from Regulation (EU) 1935/2004 (Article 16).

From which authority can a declaration of compliance for food contact material be obtained?

No authority issues declarations of compliance for contact materials. The manufacturer and the importer of the food contact material are responsible preparing the declaration of compliance. The manufacturer best knows the composition of the product and the manufacturing process, and they must have had laboratory tests performed on the contact material to establish whether or not constituents in the material migrate into the food and the amounts involved. The importer must request the manufacturer to provide a declaration of compliance when importation begins.

What legal information must be included in the declaration of compliance for the contact material?

The declaration of compliance must apply to the entire product and must therefore also take into account all the parts used in the contact material and also, for example, the dyes used in the labelling. The entire material must comply with the general requirements of Framework Regulation (EU) 1935/2004 and the declaration must include assurance to this effect. In addition, the declaration must demonstrate safety references for all parts of the contact material. If the contact material consists of a single constituent, only one safety reference (e.g. Plastics Regulation) may be indicated. If, for example, the contact material is made of many different materials or layers of material, a safety reference must be demonstrated for each of these separate materials or layers. For example, is the material is printed, plastic-coated board, a safety reference must be indicated for the board, plastic and printing inks.