Nordic project on food contact materials (FCM) - presented by Project leader Ågot Li Senioradviser, The Norwegian Food Safety Authority

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Nordic project FCM -control of DoC The project group: Denmark, Faroe Islands, Finland, Iceland, Norway and Sweden Focus on plastic materials (used a lot, specific legislation) Control of declaration of compliance (DoC) following the plastic materials

Declaration of compliance (DoC) Declaration of compliance (DoC) is documentation for use between trading partners DoC gives a summary of the supporting documentation of the FCM’s compliance with the legislation For food producers: DoC tells them what kind of food the FCM is suitable for

Nordic project FCM -control of DoC Project period: 2013 – 2015 Training of the Nordic inspectors in March 2014 Inspection period: 1 May to 30 November controlling producers, importers and users of food contact materials made of plastic - used the Nordic check list to control the documentation (declaration of compliance) - reported the results in an electronic system (QuestBack)

Nordic project FCM -control of DoC Expected effects: For the establishments: - Better competence and increased compliance with the requirements of FCM For the authorities: - Enhanced competence of the requirements of FCM - Improved and harmonized interpretation of compliance of FCM regarding DoC and supporting documents

Nordic Project FCM -performance measures Inspections in at least 120 establishments in the Nordic countries Control of DoC for 1-2 products in each establishment Samples for analysis of phtalate content in 22 food contact materials

Nordic project FCM -control of DoC A total of about 120 establishments Each country should inspect 25 establishments (less in Iceland and Faroe Islands) - Sweden and Faroe Islands: Food establishments - Norway and Denmark: FCM producers/importers - Finland and Iceland: Both FCM producers/importers and food establishments

Inspections in 181 establishments FCM establishments - 80 Food establishments Control of DoC for 280 products products from FCM establishments products from Food establishments 19 samples are taken for phtalate analysis Results

Food contact materials controlled Film Boxes and trays Bottles Gloves Hoses Conveyorbelts (and more)

Type of establishment inspected 80 Food establishments using FCM - meat, fish, milk, beverage, bakeries and more 54 importers of FCM (could be a food establishment or a FCM-producer) 49 producers of FCM

FCM establishments per country

FCM products from producers and importers, - number per country (of 147) Four countries contributed: –Denmark31 products –Finland56 products –Iceland 7 products –Norway53 products

Food establishments per country

FCM products from Food producers, - number per country (of 133) Four countries contributed: –Finland58 products –Faroe Islands10 products –Iceland17 products –Sweden48 products

Checklist used for control in addition to the Nordic checklist Questions about: - origin of the FCM - knowledge of legislation - traceability - documentation following the FCM (declaration of compliance - DoC) - information given in the documentation → leads to the quality of the declaration of compliance

Origin of the FCM - controlled at producers and importers 67 % of the products are from EU-countries –Germany (25 %) –Finland –Italy –France –Poland –Sweden –Netherlands (5,8%)

Origin of the FCM - 33% from third country China

Knowledge about the legislation Should know about the FCM-regulations (at least1935/2004, 2023/2004, 10/2011) The knowledge best in FCM producers -about 75% had sufficient knowledge - FCM importers ca 50% - Food producers ca 40 %

Traceability in the establishment Regulation (EU) 1935/2004, article 17: - systems and procedures to identify; from which business and to which business Results: - Most of the establishments have a system for traceability

Value of identification of the product The identification of the product and the link to the DoC is crucial for the value of the DoC Important !

Declaration of compliance -does it exist? Food FCM Yes

Information wanted in the Declaration of compliance Identity of the product and the producer/business operator Date of issuing the DoC Compliance with relevant legislation Migration of chemicals to food Dual Use Additives in the FCM (additives that are allowed in food) Specifications on the use of the FCM

Quality of DoC following the FCM Food establishments FCM establishments

What could be better in the DoC? Adequate information about –Migration of chemicals; - migration of a given substance (given a specific migration limit - SML) - migration of amount of non-volatile substances (given an overall migration limit- OML)

What could be better in the DoC? Adequate information about –Dual Use Additives are additives which are both in the Union list for food and for food contact materials (FCM) –It is important for users of FCM to know if the additives in the FCM can migrate to the food

What could be better in the DoC? Specification on use of the FCM - important for the user of the final FCM Related to information about - types of food - temperature of treatment and storage - ratio of contact surface area to volume used in the testing of the FCM

Analysis of phtalates 19 products are analysed - from all Nordic countries - includes plastic film, gloves, conveyerbelts, hoses, lids with gasket The analysis shows that phtalates are still used in producing food contact materials The use of FCM are not always in accordance with what they are meant for

Effects of controlling the FCM? YES Because: The best results in the project are from Denmark and Finland The authorities in Denmark and Finland have been controlling FCM in food - and FCM establishments for several years- the authorities in the other Nordic countries have recently started controlling FCM

Preliminary conclusions Controlling FCM should be prioritized in all the Nordic countries Competence to control FCM producers and importers should be given in the National legislation of all the Nordic countries Nordic cooperation in the FCM control gives results

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