Overview
The European Committee for Food Contact Materials and Articles (CD-P-MCA) initiated public consultations on February 5, 2020 for two new draft documents relating to food contact materials. The CD-P-MCA is a Steering Committee of the Council of Europe (COE), under the aegis of the European Directorate for the Quality of Medicines and Healthcare (EDQM). Its purpose is to develop standards and examine questions related to the safety and quality of food contact materials, particularly those used for both foodstuffs and pharmaceuticals. Documents issued by the CD-P-MCA are intended to support resolutions issued by the COE, many of which address the safety of substances that are not subject to harmonized European legislation. The COE resolutions, and any associated documents, are not legally binding but are widely respected.
The first draft document released by the CD-P-MCA, Guiding Principles for Food Contact Materials and Articles, provides general guidance on the use of substances in the manufacture of food contact materials and articles. It is intended particularly for those substances that are not covered by material-specific legal provisions but rather only the provisions of Regulation (EC) No 1935/2004 on materials and articles intended to come into contact with food. The draft document summarizes the legal requirements applicable to food contact materials, including the need for a risk assessment to ensure safety, as well as labeling, traceability, good manufacturing practices, Declarations of Compliance, and compliance testing.
The second draft document, Technical Guide on Paper and Board Materials and Articles for Food Contact, appears to support a potential future COE resolution on food contact paper and board. It addresses requirements for all food contact materials produced from paper and board (e.g. plates, cups, baking and filter papers, food packaging, kitchen towels, napkins, etc.), including those made from recycled fibers and products that are coated, glued, printed, or composed of several layers. The draft Technical Guide does not apply to adhesives, printing inks, or plastics. The draft Technical Guide summarizes both general and specific requirements applicable to food contact paper and board, including compliance testing, considerations for assurance of a functional barrier to migration, microbiological purity, and sensory/organoleptic testing. It also reviews requirements for compliance documentation and Declarations of Compliance.
To submit comments and feedback on the draft documents, interested parties must use the designated online form for comments, which are linked within each consultation document. Comments must be sent in English or French to the email address specified in each consultation document by March 16, 2020. Steptoe is ready to assist those that may be interested in responding to the consultation.
