Introducing new additives to food contact packaging

Since 2011, food packaging has been subjected to more stringent regulations than ever. Plastic materials are governed by legislation detailing various aspects of risk and hazard assessment, migration behavior and toxicity. Victoria Sayer, Global Regulatory Manager at ColorMatrix, explains to BP&R what food packaging manufacturers in the plastics industry should be aware of when introducing new additives to products.

The use of chemicals in food packaging is much debated and consumer safety is of paramount importance. Legislation is understandably strict, but those working in the plastics industry must ensure compliance to protect both consumers and their customers’ brands. In today’s global market, regulatory issues are complicated by the fact that brand owners are often selling food products into multiple countries governed by different – and changing – legislative frameworks.

There are numerous regulatory considerations to be taken into account when introducing a new additive to a plastic and specialist advice is recommended to help navigate the changing regulatory environment. What should plastics producers selling food contact packaging be looking for when planning changes to their chemicals portfolio?

What chemicals are being used?

Building a hazard profile of the new additive is key to establishing the potential risks involved in its use. The supplier should be able to provide information on the structure of the new chemical and this can help to identify any potentially hazardous properties. Sufficient toxicological data also needs to be available.  Regulators typically assess not only the hazard of a material, but the risk based on the use level, its migration behaviour and ultimately how much the consumer will be exposed to. Any regulatory approvals granted would take all these factors into consideration and a material will only be approved if consumer exposure is many magnitudes lower than any dose level of concern.

What is the application?

The end use of the plastic should also be taken into consideration. Factors such as the food types, contact time and temperature are all important parameters and the behaviour of chemicals under the appropriate scenario needs to be understood. In addition, the use patterns of packaging types need to be considered. For example, use of chemicals in applications such as bottle beverages may lead to much wider consumer exposure than use in a plastic utensil. The contact time of a beverage with its packaging is also likely to be much longer than the contact time of a foodstuff with a plastic utensil. These are all important factors when determining if consumer exposure to a chemical from a food contact application is safe. Food contact applications are heavily regulated but plastics producers should remember that brand owners are often cautious and demand diligence that goes above and beyond minimum legal requirements.

Where will the product be sold?

The plastics industry is global, but regulatory restrictions vary from region to region. Different requirements must be met to comply with food contact legislation. For example, there are detailed regulatory frameworks in four major regions: Europe, the US, China and Latin America (Mercosur). Whilst there are similarities in these four regions, the lists of permitted chemicals and the way in which regulators deal with approvals differs in each jurisdiction, and for global players it is critical that they have an understanding of all regulatory frameworks to ensure compliance.