Food Contact Materials

Most of the food and drink we buy comes packaged. Food packaging has many benefits – it helps to protect the food, preserving its quality and extending its period for safe consumption, thereby helping to reduce food waste. However, when packing food it is critical to ensure that the product does not inadvertently then become contaminated with potentially harmful substances transferring to the food from the packaging material itself. This also applies to any other materials that can come into contact with the food during its lifecycle; including conveyor belts, pipework and related production equipment, cooking utensils, crockery, cutlery, domestic storage containers etc – the so called ‘Food Contact Materials’ (FCMs).

Any chemical migration into food is important because it can have two impacts:

• food safety - some substances used to manufacture packaging materials could be harmful if they migrated to the food and ingested in a large enough quantity.
• food quality - migrating substances may impart taint or odour to the food and so reduce consumer appeal.

There are thousands of substances used in the manufacture of food contact materials but the determination of only a limited number of these have been standardised for food contact materials and food simulants through standardisation bodies such as CEN.

CEN methods have also been published for the determination of the overall migration (the sum of all non-volatile substances that migrate from a plastic FCM into a food or food simulant). The published methods also describe how a migration test should be carried out.

Our services conduct targeted and non-targeted analysis of known and unknown migrants in FCM’s as well as migrants transferring from FCM’s into food simulants (simple media intended to mimic foods) and foods themselves. Analysis of migrants (intentionally or non-intentionally present in the FCM) is carried out using a range of advanced chromatographic and mass spectrometric techniques including:

• Headspace gas chromatography with mass spectrometry detection (HS-GC-MS)
• Liquid injection GC-MS
• GC with high resolution mass spectrometry detection e.g. GC-(Q)TOF-MS
• Liquid chromatography with high resolution mass spectrometry detection e.g. LC-(Q)TOF-MS
• Inductively coupled plasma (ICP)-MS

Intentionally Added Substances (IAS)

IAS are known ingredients in food contact materials which can migrate into foods such as monomers, catalysts, solvents, suspension media, additives, etc.

At Fera we test to determine the concentration of the IAS in a material or article and its migration into food simulants and foodstuffs.

Non-Intentionally Added Substances (NIAS)

NIAS are known or unknown isomers, impurities, reaction products and breakdown products of these ingredients as well as possible contaminants from the manufacturing process such as recycled materials, irradiated materials or contamination from indirect food contact sources such as printing inks, external coatings, adhesives, secondary packaging.

Fera has extensive experience in the detection, identification and quantification of NIAS in a range of material types and their migration into food simulants and foodstuffs.

Following the United Kingdom’s (UK’s) exit from the European Union (EU), legislation on food contact materials and articles is now assimilated in the UK.

All FCMs must comply with the requirements of assimilated Regulation 1935/2004, which sets out the general framework. Assimilated law outlines the authorisation requirements for these substances:

• for plastic monomers and additives in Regulation 10/2011
• for active/intelligent materials in Regulation 450/2009
• for recycled plastic processes in Regulation 282/2008
• for regenerated cellulose film in The Materials and Articles in Contact with Food (England) Regulations 2012, The Materials and Articles in Contact with Food (Scotland) Regulations 2012 and The Materials and Articles in Contact with Food (Wales) Regulations 2012

Food contact materials authorisation guidance | Food Standards Agency

The current EU legislation for food contact materials can be found at: https://food.ec.europa.eu/food-safety/chemical-safety/food-contact-materials/legislation_en

The FSA provides guidance on FCM authorisation requirements.

https://www.food.gov.uk/business-guidance/regulated-products/food-contact-materials-guidance#placing-fcms-on-the-market-in-great-britain

https://www.food.gov.uk/business-guidance/food-contact-materials-regulations

The FSA provides information on banned or restricted products such as plastic kitchenware from China and Hong Kong under assimilated Regulation (EU) No. 284/2011, including First Points of Introduction (FPIs).

They also regularly issue guidance to food industry representatives and other stakeholders on a range of topics, often as a result of new regulations coming into force.

EURL-FCM Technical Guidance Documents

https://joint-research-centre.ec.europa.eu/eurl-food-contact-materials/eurl-fcm-technical-guidelines_en

• Testing conditions for kitchenware articles in contact with foodstuffs: Plastics, Metals, Silicone and Rubber, Paper & Board
• Guidance on sampling, analysis and data reporting for the monitoring of mineral oil hydrocarbons in food and food contact materials
• Guidance on characterisation of the composition of plastic multi-layers
• Practical guidelines on the application of migration modelling for the estimation of specific migration
• Guideline on testing migration of primary aromatic amines from polyamide utensils and for formaldehyde from melamine-based kitchenware in support of Regulation (EU) No 284/2011 on imports from China and Hong-Kong
• Calculator for the correction of the experimental specific migration for comparison with the legislative limit
• Guidelines to evaluate method performance and conduct validation studies of analytical methods for FCM