BEUC – the European consumer confederation – recently released the report ‘More Than A Paper Tiger. An investigation devoted to toxic and hazardous substances detected through laboratory analysis in various materials intended to come into contact with food. Paper and cardboard objects, sometimes intended even for children. The occasion is worth opening a Pandora’s box, however, which concerns almost all MOCAs (Materials and Objects Intended to Come into Contact with Food) and not just those made of cardboard.
Radio Article 1 interview with Dario Dongo on chemical safety risks associated with food contact materials
Plastic vs. bioplastics, paper and cardboard
Plastic is in the eye of the storm today as never before because of its impact on the environment and human health. In the face of alarming data onpollution of seas, reservoirs and waterways, wastewater. Leading to the dispersion of microplastics, including into the atmosphere, and their entry into the food chain. Micro- and nanoplastics expose the human and animal population to serious health risks, to date without adequate consideration by food safety (and health, in general) risk management authorities.
European policy has taken some steps forward, with the Circular Economy Package and theSingle-Use Plastics ( SUPs) Directive. Having defined the so-called waste hierarchy-reduction and reuse in the first place -there has finally been a ban on the marketing of certain single-use plastic items, such as including plates and cutlery (but not also, shamefully, glasses).
Some retail groups-from Ikea to UNES-have decided to ban single-use plastics in advance of legislative deadlines. Others, such as Coop Italia, worked ahead of time on material reduction as well as the use of recycled plastics and bioplastics. Even in food service something is starting to move, with Starbucks’ commitment to eliminate plastic straws everywhere. And the modest commitment, indeed greenwashing, of McDonald’s. Which in September will replace some containers, only in the UK, with partially recycled cardboard items.
As a result, the scientific community and consumer groups are beginning to turn the spotlight on alternatives to plastics. Without, moreover, having solved the problems of hydrocarbon plastics and the more than 5,000 toxic substances in everyday objects (MOCAs as well as cosmetics and other consumer goods, including furniture and cosmetics). With attention not only to carcinogens and genotoxic substances but also to endocrine disruptors, the shame of the European Commission.
Paper, cardboard, and inks. Chemical safety issues
Paper-in its many applications-is undoubtedly one of the raw materials most likely to replace petroleum derivatives. Especially in food packaging, where it is already the second most used material, after plastic. Having, among other things, an overall environmental impact that is also more advantageous than bioplastics, provided that the sustainability of the supply chain (which must definitely exclude the use of deforestation) is ensured. Recycled paper, however, may hide some chemical safety pitfalls related particularly to ink residues. To the point of being banned-at least in some countries, such as Italy-in the production of items and packaging intended to contact certain foods.
Thus, the safety assessment of the most common paper and cardboard objects has a complexity that varies due to the type and number of substances added to paper and cardboard. Cups and mugs, plates and packages are indeed often printed with ink and fitted with barrier coatings, necessary to ensure impermeability to liquids and/or grease. And the substances included in printing and waterproofing processes-on objects made of paper and cardboard, but also of plant materials (e.g., bamboo, wood) rather than plastics-are precisely those with the most critical issues. Critical issues that stem first and foremost from serious gaps in European law, which to date lacks a framework capable of fully guaranteeing the chemical safety of MOCAs and more generally of commonly used goods.
Paper, cardboard, and inks. The report of European consumers
The ‘More Than A Paper Tiger‘ report was published by BEUC, the confederation that coordinates some 40 national consumer associations in Brussels, including Altroconsumo, Spain’s OCU and several others. (1) This is a brief survey of 76 samples of consumer items made of cardboard, much of which is set to replace plastic starting in 2021. Coffee cups, plates, straws, napkins, bread bags etc. As well as packaging for foods such as pasta, cereal, and candy.
The hazardous substances on which attention has focused are primary aromatic amines. A family of compounds-some of which are carcinogenic, others ‘only’ suspected of being so-that can develop from licensed substances or substances used to color products. As well as in so-called photoinitiators (including benzophenone), which, upon exposure to UV light, release substances that activate paint polymerization reactions. With whose exposure endocrine interference and suspected carcinogenesis are associated.
Among the 76 samples analyzed, primary aromatic amines were detected in 17% of cases (13 samples) of which 9 were ‘above limits.’ On items such as straws and bags to hold candy, therefore also intended for children. With reported values in the range of 5-65 micrograms per liter (ppb). Photoinitiators and other substances related to the use of printing inks were then detected in almost all packaging samples tested (only five samples tested negative). Two samples contained benzophenone at high levels, and in 50 samples there was evidence of potential migration exceeding the limits of the Swiss ordinance regulating precisely inks in contact materials (600 ppb for benzophenone, 10 ppb for substances not covered by Swiss law).
The Swiss ordinance is used as a regulatory reference precisely because, as also highlighted in the report, one of the major critical issues involving paper (possibly printed) is the absence of harmonized legislation at the European level. Only a few member states-Italy, Germany, France, the Netherlands, and Belgium-protect consumers against such risks. With clearly asymmetrical levels of public health protection-and burdens on business that are also relevant to competitiveness. The use of recycled paper, for example, is allowed in Italy only for dry solid foods (e.g., salt, sugar, rice, dry pasta). While in Germany it is tolerated on all types of food ‘subject to verification of compliance‘.
BEUC, the dark side of the relationship
BEUC insinuates that the use of printed paper and paperboard for food contact carries the risk associated with the presence of problematic chemicals, some of which have not even been evaluated by EFSA. However, the greatest criticalities are attributed, more than to paper, to complex chemical mixtures – dyes, binders, solvents and additives – where more than 5,000 different substances can converge. Which, it is pointed out, can be used not only on paper but on many other materials.
The instrumentalization of the report has thus already begun. PRO.MO – a group of single-use plastic tableware manufacturers – took it up emphatically on its website, titling the statement ‘Paper and cardboard food packaging, possible health risks‘. On closer inspection, by the way, the BEUC report is not transparent on some points. And some assessments may not be entirely agreeable. When assessing the presence of primary aromatic amines, for example, it is unclear whether the threshold defined by the European Plastics Regulation (10 ppb) or that suggested byI BfR, the German Institute for Risk Assessment (equal to 2ppb, 5 times lower) was used. In fact, the BEUC report states that ‘nine samples contained PAA above the limit set in the plastics regulation (10ppb) or the BfR recommendations (2ppb).’ Since analytical results are not made public, it is not known how many samples actually exceed the legal limit set in Europe for plastics (10ppb).
It begs the question then, if we assume the value of 2ppb as a safe threshold, how many plastics on the EU market today exceed these limits? Will a new study of a few dozen samples, such as the one under review, be enough to answer? Is BEUC’s priority to discredit a viable alternative to petroleum plastics? Clarification would be helpful. Instead, our priority is to protect public health by affirming the urgent need for a holistic regulation of hazardous chemicals in their various uses. Pandora’s box is open.
#Égalité!
Dario Dongo and Luca Foltran
Notes
(1) BEUC (2019). Report More than a paper tiger. European consumer organizations call for action on paper and board food contact materials, https://www.beuc.eu/publications/beuc-x-2019-042_more_than_a_paper_tiger_test_summary_food_contact_materials.pdf?ref=drnweb.repubblica.scroll-1
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
Expert in packaging and materials intended to come into contact with food substances and related legislative changes. He manages the information site foodcontactmaterials.info on European and extra-European regulations in the field of materials intended for contact with food.
