Food Contact Materials

Food Contact Materials

1. 1935/2004/ EC The European Union legislation on food contact materials began in the 1970s, the first directive is 76/893 / EEC, this directive is a framework which is to coordinate each member in the fields of legislation, make a consistent trend between different national mandatory technical requirements. The current laws and regulations is (EC) No. 1935/2004 (Regulation No. 1935/2004/ EC of The European Parliament And of The Council of 27 October 2004), which is promulgated on November 13th, 2004 and passed by the European Parliament and the European union Council. So far, the European Union involves food contact materials and products of the instruction or regulations have accumulated morethan 30.

1935/2004 / EC defined the following conditions of the product/material contacted with food: it must accord with Good Manufacturing practices (GMP), when the product contact food, shall not:

1. Release dangerous composition to human health 

2. Lead food to change ingredients which can't be accepted 

3. Reduce the sensory characteristics brought by food (make food taste, smell, color change)

Some EU member states, such as Germany, France, etc., in addition to strictly follow the EU 1935/2004, still have alocal food grade regulations must be followed, such as Germany LFGB (LMBG), France French DM/4B/COM/001-DM/4B/COM/004 and Italy bulletin (Gazzetta Ufficiale G.U) legal NO. 283 OF 30/40/1962 and local laws 21/03/1973(D.M. 21/03/73), etc.

2. LFGB In September 2005, new German regulaiton of food and food supplies LFGB replaced LMBG. It is also called "Lebensmittel–Bedarfsgegenstandegesetzund Futtermittelegsetzbuch", it was the most important basic legal documents of German food hygiene management , is the core of other special food health laws and regulations. And if pass the test, the products can get the report issued by the agencies of LFGB, which proved that "does not contain chemical poisonous material products", and can sale in the German market.

1. Special place in testing

The difference between LFGB and other food grade test is that LFGB required to do Section 30 &31 sensory test(mainly referring to smell and taste). LFGB test requirements are more stringent than the other country's test requirements, therefore LFGB test report in other countries can also be recognized.

2. LFGB authentication include the following test items:

1. composition (poisonous and harmful components)

2. Sensory test

Usually, LFGB30&31 include the following items:

1. The initial check of samples and materials

2. Sensory evaluation of smell and taste

3. Plastic sample: heavy metal test

4. Metal: composition and heavy metal test

5. Silicon resin: volatile organic compound test

6. Special materials: according to German chemical method inspection chemical hazards

3. DGCCRF From the end of 2015, the French Bureau of competition, Consumer Affairs and fraud (DGCCRF) continually updates the DGCCRF 2004-64 food grade requirements of various types of materials, published the files DM/4B/COM/001, DM/4B/COM/002, DM/4B/COM/003 and DM/4B/COM/004, instead of DGCCRF 2004-64.

•DM/4B/COM/001: for metal and alloy materials contacted with food, presented the latest food safety requirements;

•DM/4B/COM/002: Specifies the requirements of inorganic materials other than metals, especially ceramics, glass, glass-ceramic and porcelain enamel. Introduces 3 new heavy metal emissions, but with same amount of lead and cadmium;

•DM/4B/COM/003: establishes requirements for synthetic fiber made from organic materials, such as plastics, composites (multilayer) and rubber, technical indicator not changed, only update the regulatory references.

•DM/4B/COM/004: Specifies the requirements of organic materials made of plantfiber, mainly for paper and Board, regardless of whether or not a coating. Specification does not change.

4. FDA The United States food and drug administration (FDA) is responsible for the management of national drugs, food, biological products, cosmetics, veterinary drugs, medical devices and diagnostic supplies. The Food Contact Substances(FCSs) are defined by FDA as follows: A food contact substance is any substance that is intended for use as a component of materials used in manufacturing, packing, packaging, transporting, or holding food if such use is not intended to have any technical effect in such food.

The specific general requirements of food contact containers and materials are as follows:

- Factory can operation in accordance with the GMP(Good Manufacturing Practice) system

- Use the materials conformed in the regulations (U.S. FDA CFR 21 Part 170-189)

- Approved raw materials should be in line with the norms of technical indicators (U.S. FDACFR Part 170-189)

- Any new materials enter the market must be approved by U.S. FDA review and approval

2. Authentication range

Usually involved products include:

1) Toaster, sandwichoven, electric kettle, etc and food contact electrical products

2) Food storage products, tempered glass cutting board, stainless steel kitchen utensils

3) Bowl, knife, fork, spoon, cup dish and table-wares-Vessels shipping to California must comply with the California Proposition 65 regulations requirements (including the part that vessels contacted with food , external decoration, the edge of glass parts). The products include but not limited:

1) glass and ceramic products used for storage, carrying food or drinks

2) glass and ceramic products not contact with food or drinks(daily necessities).

5. China Food contact At the end of 2016, National Health and Family Planning Commission of the People's Republic of China published 53 new national standards of food contact materials and products, thoroughly clean and consolidate the old standards. In recent years, with new national standards of food contact materials released, the new standard system of food contact materials are also shaped.

After the implementation of the new national standards, food contact materials and products need to be aware of the following points:
1. Migration test follow General principle of migration test and General principle of pretreatment of migration test;
2. General safety principles of FCM for use principle, label, DOC etc.;
3. GB 9685 for additives;
4. Production under Manufacture practice for the production of FCM;
5. Commodity standards for raw substances, resins and/or final products. 

Implementation dates of the new standards are as follows: