Food contact materials must have a safe chemical and microbiological quality, and they must also otherwise fulfil the legal requirements. An important part of safety is the traceability of food contact materials. This basically means that there is documentation about the origins of the food contact materials, what they have been used for and when, or where they have been delivered.
The safety and regulatory compliance of food contact materials is formed by several requirements that must all be fulfilled. Each operator in the supply chain has their own role and responsibility in ensuring safety. The main responsibility for the general safety and regulatory compliance of the material lies with the contact material operator who manufactures, imports or supplies/wholesales the food contact materials.
The chemical composition of the contact material must be as inert as possible. They cannot release their own substances into the food in such quantities that the food becomes a threat to human health. Also, the food’s composition or its sensory qualities (smell, taste, appearance) may not become undesirable due to an effect from the food contact material.
In ensuring safety, it is vital to transfer regulatory compliance statements and research data along the supply chain.
According to framework regulation 1035/2004, relevant and current data must be transferred along the supply chain. In documents, references to legislation must be presented based on the latest and current legislation (considering the changes). To maintain the product’s chemical composition, the operator must report the relevant restrictions for operating conditions, such as contact time, heat resistance and permitted end use applications.
Ensuring the safety and regulatory compliance of contact materials requires the following from a contact material operator:
- Managing their process and the product
- knowledge of legislation, including material-specific directives
- sufficient knowledge of the (raw) materials used
- supervision of documentation and ensuring traceability – documents such as research data and declarations of regulatory compliance must be easily and reliably linked
- testing the regulatory compliance of the materials and articles
- risk assessment
- data maintenance and ensuring its currency
The own-check requirements of a food contact material operator are explained further under “Own check of a food contact material operator.”
In trade between companies, chemical safety is demonstrated with documents showing that the materials and articles are suitable for use with food.These documents can include a declaration of compliance, test results and/or risk assessment results. These documents must show which legislation, recommendations or risk assessments the safety and regulatory compliance of the materials and articles is based on.
The consumer must be able to recognise the materials and articles that can be used in contact with food, and thus the materials and articles must clearly include symbols that prove the suitability for use with food. The ensure long-term chemical safety, the consumer is also through package labelling provided with usage guidelines for the safe use of the material or article.
The package labelling requirements for contact materials (for consumers) has been regulated in the framework regulation on contact materials 1935/2004.
The responsibility of the food industry companies and consumers is to follow the instructions on the contact material packaging or documentation, and thus a consumer or food industry company bringing the contact material in contact with food has the final responsibility to ensure that the contact material in use is suitable. The food contact material-related own-check requirements of a food industry operator are explained further under “Own check of a food industry operator".