Plastic food contact materials containing bamboo flour or other unauthorised vegetable fibres
Can plastics containing bamboo fibre or other unauthorised vegetable fibre manufactured for food contact material use be imported into or manufactured in Finland?
Plastic products containing bamboo fibre or other unauthorised vegetable fibre (e.g. rice flour) are not allowed to be imported into Finland. Neither may they be manufactured in Finland for use as a food contact material as long as the vegetable fibre used as a raw material has not been included in the list of authorised substances in the Plastics Regulation (EU) 10/2011. This ban does not apply to food contact materials made solely of bamboo and which do not contain plastic.
Why is it not allowed to import these products into or manufacture them in Finland?
Plastic products containing bamboo or other unauthorised vegetable fibre do not comply with the EU’s safety requirements laid down for food contact materials. No risk assessment of the raw materials concerned has been performed and they are not included on the positive list of authorised ingredients (Annex I) in Plastics Regulation (EU) 10/2011. These products have also been marketed misleadingly. Misleading marketing is prohibited under General Regulation (EC) 1935/2004 on materials and articles intended to come into contact with food.
What happens to plastic products containing bamboo fibre and other unauthorised vegetable fibre intended for food contact that are already on the market?
If such products are already in retail sales in Finland, they must be withdrawn from sale. Guidelines on the withdrawal of products can be found on the Finnish Food Authority's website.
Can consumers continue to safely use products containing bamboo fibre or other unauthorised vegetable fibre?
Consumers are recommended to stop using such products that they have already acquired because there is no certainty as to the safety of these products. However, short-term use has not harmed the health of the consumer and the appearance of harmful effects requires very long-term and repeated use.
What risks are involved in plastic products containing bamboo flour or other unauthorised vegetable fibres?
Since the safety of bamboo flour or other unauthorised vegetable fibres has not been assessed as an ingredient in plastic products, there can be no certainty as to the safety of their use in this way. Where unauthorised vegetable fibres have been used in plastic products, migration of formaldehyde and melamine has been found in many cases to considerably exceed migration limits. Formaldehyde and melamine are harmful to human health and their migration in these products could have been even greater than in similar products made of plastic only. Plastics Regulation (EU) 10/2011 lays down the migration limits for formaldehyde and melamine that may not be exceeded in plastic food contact materials.
What products have, for example, unauthorised vegetable fibres been used in?
Unauthorised vegetable fibres have been used in the manufacture of various-take away beakers, children’s tableware and cutlery, for example. Vegetable fibres have been added to plastics (i.e. melamine, polypropene) as a filler to reduce the amount of plastic in the product. However, these are plastic products with ordinary plastic properties and, for example, do not biodegrade in nature.
If a product contains bamboo flour, corn flour and melamine resin is it a plastic food contact material in compliance with Plastics Regulation (EU) 10/2011?
The product does not comply with Plastics Regulation (EU) 10/2011 because bamboo flour is not on the list of authorised substances in the Regulation. A product is considered as being a plastic product because of the melamine resin contained in it and it is not up to the operator to decide whether the product is a plastic one or not.
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 (EC) 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 import restrictions in Regulation (EU) 284/2011 regarding the migration of, among other things, formaldehyde and PAAs (primary aromatic amines).
How can an operator get a vegetable fibre ingredient added to the list of authorised substances in Plastics Regulation (EU) 10/2011?
The operator must apply for the authorisation of the vegetable fibre in accordance with General Regulation (EC) 1935/2004 on materials and articles intended to come into contact with food. Information about the safety, etc. of the substance is sent to the Finnish Food Authority which forwards it to the European Food Safety Authority, which carries out a risk assessment of the substance. Under the European Commission’s policy, authorisation of vegetable fibres must be applied for on a case-by-case basis. If EFSA’s risk assessment opinion is positive, it progresses to the Commission to be taken into account in the following change to the Plastics Regulation. Instructions for authorisation can be found on the Finnish Food Authority's website.
Under General Regulation (EC) 1935/2004 on materials and articles intended to come into contact with food, ingredients from food contact materials may not migrate into food in quantities large enough to endanger human health, or to bring about an unacceptable change in the composition of the food or a deterioration in its organoleptic properties. More detailed provisions on the safety of plastic food contact materials are laid down in Plastics Regulation (EU) 10/2011. The Regulation also contains a list of so-called authorised substances (Annex I) which lists the substances that may be used in the manufacture of food contact plastics. A risk assessment of the substances concerned has been performed by the European Food Safety Authority (EFSA) and restrictions of use, quantitative restrictions or migration limits have been laid down for some of the substances that food contact material manufacturers must comply with.
The European Commission has stated views on the safety and compliance of food contact materials containing unauthorised vegetable fibres. A summary of the view can be found here: