The European Commission is finally set to reform-slug rules on the safety of materials and articles intended to come into contact with food (MOCA or FCM, Food Contact Materials). (1)
The hypotheses of the revision of Regulation (EC) No. 1935/04 were subjected to public consultation, now nearing its deadline on 29.1.21. (2)
Next, the lucid position expressed by Professor Alberto Mantovani on behalf of the Istituto Superiore di Sanità (ISS).
EU Consultation on MOCAs
The new regulation on MOCAs – food packaging, tableware, food processing equipment, etc. – could see the light of day by the fourth quarter of 2022. (1)
The regulatory review has the following objectives:
– Ensure food safety and a high level of public health protection,
– Reduce the presence and use of hazardous chemicals,
– Take into account the latest developments in science and technology,
– Support innovation and sustainability by promoting safe, reusable and recyclable solutions and helping to reduce the industry’s environmental impact.
Alberto Mantovani’s comment
The text of the proposed regulation on MOCAs is analyzed and commented on by Professor Alberto Mantovani, toxicologist, research executive of the Istituto Superiore di Sanità(ISS), former president of the European Society of Teratology. As well as a longstanding member for 15 years of the Scientific Panel on Feed and Pesticides at EFSA(European Food Safety Authority), where he continues to work as an external expert.
‘The documentpresents a number of valuable points highlighting the potential risks to public health and sustainability from weak and/or inconsistent regulation of food contact materials in the EU’ (Alberto Mantovani, ISS).
Points for improvement
Several aspects need to be reviewed, Professor Mantovani explains.
‘There is a clear need for a stronger, science-based regulatory framework throughout the Union, based on the principle “a substance, an evaluation” and to promote cooperation, exchange and sharing among EU scientific agencies (primarily EFSA and ECHA; also taking into account EEA and DG SANTE scientific committees).
Risks and emerging issues
‘There are a number of emerging issues, which include, for example:
– nanomaterials,
– Unintentionally added substances,
– recycled materials (which could also “recycle” contaminants),
– environmental impact assessment (currently not considered by EFSA, unlike other categories of substances, such as pesticides or feed additives)’.
A new regulatory framework is needed
‘Therefore Option 1 (page 5) “Use the current regulatory framework, with Regulation (EC) No. 1935/2004 as the cornerstone” seems inappropriate. Considering the inconsistencies identified in this paper, as well as emerging issues, Option 2 “Develop a new regulatory framework, replacing the current regulation” is preferred. (3)
Otherwise, if the current regulatory framework is retained, it must be substantially updated taking into account the need for a harmonized approach across different types of FCMs and scientific evidence highlighting emerging and under-regulated issues’.
Marta Strinati and Dario Dongo
Notes
(1) Marta Strinati. Food contact materials, reform-slug slips again. GIFT(Great Italian Food Trade). 17.2.20, https://www.greatitalianfoodtrade.it/imballaggi/materiali-a-contatto-con-gli-alimenti-la-riforma-lumaca-slitta-ancora
(2) Impact assessment of the proposed Food Contact Materials regulation. See attached document
(3) Dario Dongo. Contact materials, safety issue. GIFT(Great Italian Food Trade). 9/27/18, https://www.greatitalianfoodtrade.it/imballaggi/materiali-a-contatto-questione-sicurezza
Professional journalist since January 1995, he has worked for newspapers (Il Messaggero, Paese Sera, La Stampa) and periodicals (NumeroUno, Il Salvagente). She is the author of journalistic surveys on food, she has published the book "Reading labels to know what we eat".
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
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