European Wax Federation
EWF
EWF represents the European wax producers, refiners and blenders as well as associated members from outside Europe.
ID: 35124162688-86
Lobbying Activity
Response to Revision of EU rules on food contact materials
28 Jan 2021
The European Wax Federation (EWF) welcomes the opportunity to provide input to the Inception Impact Assessment(IAA) on the Revision of EU rules on food contact materials (FCMs).
The European Wax Federation aisbl represents European (as well as a number of non-European companies) active in the manufacturing, blending and commercializing of waxes. Waxes are a complex group of materials of natural, mineral, petroleum derived or synthetic origin with many different uses. They can be used as additive or a processing and production aid in many types of food contact materials. They are also used as the sole or a predominant component of surface coatings. This is the case for instance paraffin waxes, including synthetic paraffin, and or micro-crystalline waxes and for mixtures of these waxes with each other and/or with plastics.
In general, the EWF considers the approach taken in “Prioritising the assessment and management of substances” by assigning substances to Tier 1, Tier 2 and Tier 3 categories as a pragmatic way to tackle the problem of the multitude of substances used in food contact materials. In order for our industry to cope with these new requirements, it would be imperative that the specific criteria for substances to be classified under a specific Tier as well as the corresponding information requirements are published as soon as possible.
Specifically for Tier 2 and Tier 3 substances, we note that it is the intention that the exposure of the consumer to the substance will remain a key component in the overall safety assessment of the substance. We believe indeed that exposure to a substances is critical in determining the risk as hazard alone is only part of the risk equation. Risk = hazard x exposure. Therefore, the risk associated with a particular substance is dependent upon the use of that substance.
Further clarification will be needed, however, as whether it is one hazard assessment with one risk assessment or more appropriately one hazard assessment with risk assessments related to the specific uses of the substance. Also, we consider it vital that expert stakeholders will play an instrumental role in developing the guidelines helping business operators in conducting their risk assessments as well as clearly outlining the responsibilities of supply chain actors. Tthe input of these expert stakeholders would be critical in ensuring of the workability of these guidelines.
The EWF also welcomes the creation of an integrated, more modern, simplified and digitalised system commensurate with progressing technological and IT standards, to improve accountability, information flow and compliance work. We agree that once this system is available, it will greatly help both the Competent Authorities and our member companies to carry out their duties.
While the specificity of SME’s should be taken into account, but the rules and guidance should be clear and transparent. Associations such as the EWF can play an important role in helping our members to achieve compliance, but different rules for different sub-groups of actors should be avoided. Also, our association would appreciate being involved in developing the rules that would impact our industry. We would certainly look forward to one set of harmonised rules to follow as it would ease the burden on industry and would make enforcement by competent authorities, easier and more consistent.
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