Food contact materials

Food contact materials are materials that are intended to be in contact with food. These can be things that are quite obvious like a glass, a can for soft drinks, but also machinery in a food factory or a coffee machine.

Food contact materials can be constructed from a variety of materials like plastics, rubber, paper, coatings, metal etc. In many cases a combination is used; for example a carton box for juices can include (from the inside to the outside): plastic layer, aluminium, paper, printing and top coating.

During the contact of the food contact materials with the food, molecules can migrate from the food contact material to the food. Because of this, in many countries regulations are made to ensure food safety.

Legislation

European Union

Food safe symbol used for marking food contact materials in the EU

The framework Regulation (EC) No. 1935/2004 applies to all food contact materials. Article 3 contains general safety requirements such as not endanger human health, no unacceptable change in the composition and no deterioration of the organoleptic characteristics. Article 4 set out special requirements for active and intelligent materials. Article 5 specifies measures for groups of materials that may be detailed in separate regulations of directives. Member States may maintain or adopt national provisions (Article 6). Articles 7-14 and 22-23 deal with the requirements and application for authorisation of a substance, modification of authorisation, the role of the European Food Safety Authority, the Member States and the Community. Article 15 is about labeling of food contact materials not yet in contact with food. Article 16 requires a declaration of compliance and appropriate documentation that demonstrate compliance. Articles 17-21 deal with traceability, safeguard measures, public access of applications, confidentiality, and data sharing. Article 24 sets out the inspection and control measures.

Specific measures for materials and articles such as ceramics, regenerated cellulose, plastics, gaskets and active and intelligent materials, and substances such as vinyl chloride, N-nitrosamines and N-nitrostable substances in rubber, and epoxy derivatives, exist.

United States

The U.S. Food and Drug Administration (FDA) considers three different types of food additives:

• Direct food additives - components added directly to the food
• Secondary direct food additives - components that are added to the food due to food treatment like treating food with ionic resins, solvent extraction
• Indirect food additives - substances that may come into contact with food as part of packaging or processing equipment, but are not intended to be added directly to food

The food contact materials are described in the Code of Federal Legislation (CFR): 21 CFR 174 - 21 CFR 190. Important starting points are:

• 21 CFR 175 Indirect food additives: Adhesives and components of coatings
• 21 CFR 176 Indirect food additives: Paper and paperboard components
• 21 CFR 177 Indirect food additives: Polymers

To this materials additives may be added. Which additives depend on the additive and on the material in which it is intended to be used. There must be a reference to the paragraph in which the additive is mentioned and the restrictions (for example only to be used in polyolefines) and limitations (max 0.5% in the final product) must be respected. See below for part in which additives are described: 21 CFR 170 Food additives

• 21 CFR 171 Food additive petitions
• 21 CFR 172 Food additives permitted for direct addition to food for human consumption
• 21 CFR 173 Secondary direct food additives permitted in food for human consumption
• 21 CFR 178 Indirect food additives: Adjuvants, production aids, and sanitizers
• 21 CFR 180 Food additives permitted in food or in contact with food on an interim basis pending additional study

Polymers or additives can also be regulated in other ways with exemptions; for example:

• Threshold of regulation
• Food contact notification
• Private letters
• Prior sanctioned food ingredient
• Generally recognized as safe (GRAS)

See also

• Food safety
• Packaging and labeling