April 15, 2024

Feedback to the draft proposal on food safety for plastics food contact materials (update to quality control rules)

FEAD, the European Federation for Waste Management and Environmental Services, representing the private sector waste and resource management industry across Europe, welcomes the Commission’s initiative to increase quality control under Regulation (EU) No 10/2011 and Regulation (EC) No 2023/2006 on plastic food-contact materials. However, FEAD points out that the text version requires minor amendments for greater clarity

FEAD underlines that plastic recyclates fall within the scope of Regulation (EU) No 2022/1616 where the incidental contamination of polymers is already regulated. We understand that plastic recyclates do not fall within the scope of Articles 3a and 8 of the amended Regulation (EU) No 10/2011 and therefore ask for clarification in this respect.

In the context of Annex 1 of the Amended Regulation (EU) No 10/2011, which is headed ‘substances’ and then lists ‘monomers or other starting substances’, FEAD understands that the term ‘substance’ in Art. 3a in its first occurrence and in Art. 8 (1) refers to monomers or other starting substances used in the manufacture of plastic materials and articles. Consequently, the term ‘substance’ needs to be replaced in these paragraphs by “monomer or other starting substance” to clarify the text. This replacement is necessary to avoid confusion as to whether or not plastic recyclates are included in the ‘substance used to produce articles’.

It is important to note that a general definition of “substance” is not advisable as the term is used with different meanings and therefore the text itself needs to be clarified.

In conclusion, FEAD ensures the commitment of the waste management industry to advance sustainable solutions that safeguard both public health and environmental objectives, especially in plastics food contact material.

FEAD is the European Waste Management Association, representing the private waste and resource management industry across Europe, including 19 national waste management federations and 3,000 waste management companies. Private waste management companies operate in 60% of municipal waste markets in Europe and in 75% of industrial and commercial waste. This means more than 320,000 local jobs, fuelling €5 billion of investments into the economy every year.