Listing approved substances and materials for food contact in Europe: ideas for a better use and further evolvement of the present system. A contribution for discussion

Abstract

The European regulation of food contact materials (FCMs) focuses on the authorization and legal listing of approved substances introduced into the manufacturing process. Initially, the substances were toxicologically evaluated merely as such. Gradually, also their reaction products and impurities were considered for a material and application described by the petitioner. Today, this is the most laborious parts for both the petitioner and the risk assessors. However, manufacturers other than the petitioner can usually make little use of it, as only the substance is listed. Already minor changes in the present listing would be helpful, such as adding the date of listing, the assessment body in case of national lists and a link to the EFSA opinion or analogous report, if existing, that describes what the evaluation covers. However, lists could also be a driver for further improvements. It is suggested to separate the listing of approved substances (only evaluated as such) and of materials (intermediate products and final FCMs). These lists should cover all types of FCMs. Materials may be listed by the product name, clarifying the identity, facilitating communication within industry and liberating market forces asking for solid compliance work. Entries may be from the petitioning process, but also from the official control of the compliance work of industry. However, the main input might come from private bodies that are certified to evaluate according to EFSA guidance, given that these are named in the list and their approval is spot-checked by authorities. It is expected that many business operators prefer buying approved (listed) materials and that a corresponding list would become a driver for improved compliance work. The list of approved substances is an important tool for evaluating and approving these materials.