European Enamel Association
EEA
The European Enamel Association (EEA) represents the porcelain enamel industry sector in Europe.
ID: 836646841073-83
Lobbying Activity
Response to Revision of EU rules on food contact materials
29 Jan 2021
The Porcelain Enamel Industry believes a revision of the Framework Regulation should include:
1) The concept of exposure.
2) A focus on final materials and articles. Assessments should be based on final articles and only on substances that migrate from the FCM to which consumers are exposed.
3) One set of rules to follow and to market products in multiple Member States, in order to avoid being prevented from selling products in certain Member States (Enforcement of Mutual Recognition principle).
4) The clarification of the role of the Council of Europe in the production of FCM Guidelines and the inclusion of industry stakeholders in the process.
5) The centralized recognition of Delegated bodies at EU level and their modus operandi in order to ensure consistency in conformity assessment and avoid mistrust among Member States. Industry audits on quality systems should be considered as means of supporting demonstration of compliance.
6) A common platform to share new data and scientific evidence with relevant stakeholders
The Porcelain Enamel Industry believes a revision of the Framework Regulation should avoid:
1) Positive lists, as they are conceived for starting substances and do not cover substances migration from the final articles. Also, non-harmonized lists cause obstacles due to the fact that different Member States have different lists. Finally, in our case, the enameling process is not a coating process, but a real transformation process for the chemicals involved, invalidating the purpose of positive lists. For FCM it is not justified to ban a starting substance due to hazard only. In some cases starting chemicals are hazardous but, by the time they are transformed into an FCM, the risk for the consumer is neutralized.
In case the EC decides to opt for a revision, the Porcelain Enamel Industry deems it necessary to:
1) Publish the criteria and information requirements for substances in Tier 1 as soon as possible.
2) Understand substitution of a substance in a complex and lengthy process, essential to ensuring the safety and functioning of the final FCM. Having identified a potential substitute, it can take many years for the FCM to be commercialized using a substitute.
3) Grant reasonable transition timings.
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