Is bamboo fibre authorised on the positive list of Annex I of Plastics Regulation (EU) 10/2011?
Bamboo fibre and flour are not on the positive list of authorised ingredients in Plastics (EU) Regulation 10/2011
If a material contains bamboo flour, corn flour and melamine resin, is it a plastic contact material under the Plastics Regulation?
No, because bamboo flour is not on the list of authorised ingredients in the Plastics Regulation. However, the product is considered as being a plastic product due to the melamine resin it contains.
If the material contains melamine resin (albeit only a small amount), it is classified as a plastic product which must comply with the requirements both of Framework Regulation (EU) 1935/2004 and of Plastics Regulation (EU) 10/2011. In addition, the import of melamine and/or polyamide contact materials and articles from China and Hong Kong are also subject to the requirements of the import restrictions in Regulation (EU) 284/2011 regarding the migration of, among other things, formaldehyde and PAAs (primary aromatic amines).
Can an operator import plastic products containing bamboo fibre or flour to Finland?
New lots of plastic products containing bamboo fibre must not be imported at this time because their regulatory compliance issues are pending in the European Commission. Products already on the market can be sold out as long as tests has shown that the limit values for melamine and formaldehyde migrated to food are not exceeded. Also labelling must clearly indicate that they are a plastic product and are not marketed as eco-friendly and biodegradable when they are not.
What risks are involved with plastic products containing bamboo flour?
The products do not comply with the requirements of Plastics Regulation (EU) 10/2011 and thus do not meet the general requirements for chemical inertia (stability) for all contact materials set out in Framework Regulation (EU) 1935/2004. Significant excesses in the migration of formaldehyde or melamine have in many cases been detected in these products. The Plastics Regulation has laid down a group limit for migration of 15 mg/kg for formaldehyde. Under Regulation (EU) 284/2011, the migration limit for formaldehyde for melamine contact materials is also 15 mg / kg. The products have not been recognised as plastic products in border control and this is why examinations are not required for them under the Plastics Regulation and Regulation (EU) 284/2011. This is why there may be products on the market whose safety has not been verified by migration examinations. In addition, these bamboo plastic products have been marketed misleadingly as eco-friendly alternatives to plastics. This being the case, they have yet in this respect to meet the requirements of Framework Regulation (EU) 1935/2004.
How am I allowed to market the bamboo plastic containers I have for sale?
When marketing plastic products containing bamboo, attention must be given to ensuring that the consumer does not get the wrong idea about the eco-friendliness and recyclability, etc. of the products concerned. The consumer must be aware that it is a plastic product even though it contains bamboo fibre.
Is it compulsory to provide detailed information about the bamboo flour or fibre contained in plastic container packaging?
It is important that the consumer does think that the product is only made of bamboo fibre but to be aware that it is a plastic product containing bamboo fibre. Melamine is a plastic that does not degrade and so nothing to that effect must be indicated on the packaging. On the other hand, there is no need to indicate exact information about the composition in the labelling. However, the plastic type should be indicated for recycling to be successful. The requirement to indicate the type of plastic on the packaging is not, however, based on food safety legislation.