FCMs with no specific EU measures

FCMs with no specific EU measures

Assessment of the current situation concerning food contact materials for which there are no specific harmonised measures at EU level

Commission Regulation (EC) No 1935/2004 is the framework legislation for food contact materials. The purpose of the Regulation is to ensure the effective functioning of the internal market for materials and articles intended to come into contact directly or indirectly with food and secure a high level of protection of human health and the interests of consumers.

The Regulation sets out general safety requirements for all food contact materials under Article 3 as well as a general obligation on good manufacturing practice (GMP), the rules for which are laid down in Commission Regulation (EC) No 2023/2006. Specific measures for groups of materials and articles may also be introduced. Specific EU measures are in place for plastics, processes for recycled plastics, regenerated cellulose film, lead and cadmium from ceramics and active and intelligent materials and articles. See section II on our page on legislation for more information.

In the absence of specific EU measures, Member States may maintain or adopt their own national provisions on food contact materials. National legislation is in place in the majority of EU Member States, setting out individual rules on different materials and substances. These may differ from one Member State to another.

The European Commission's Joint Research Centre (JRC) has completed a study which provides a comprehensive description of the current situation concerning food contact materials for which there are no specific measures at EU level. The study maps the current industry supply chain and provides detailed information on the current national measures or other measures in place for these materials.

The study is now published and available via the JRC website.

The Commission is in the process of assessing the results of this study and considering what possible steps might need to be taken in the future concerning the regulation of food contact materials in the EU. The Commission will firstly undertake an evaluation, which will build on the work of the JRC and help assess the suitability of the current EU framework both for the harmonised and non-harmonised sectors.

Certain constituents of printing inks used in or on printed FCMs may endanger human health if they transfer into food. This was highlighted by Germany in its notification on national rules for printing inks. In response to the notification, the Commission has therefore additionally started work on a specific initiative on printed food contact materials to address this issue at EU level.

The Commission is also assessing the use of compliance documentation in the supply chain and has recently completed a survey directed at competent authorities, stakeholder associations, and business operators. The survey is now closed and the results are currently being analysed.

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