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Gustaaf Bos Consulting

Provide consultancy expert support to European Federations Association(s),national associations and companies that hire my services for all kind of food contact materials (e.g.

Lobbying Activity

Response to Restrictions on bisphenol A (BPA) and other bisphenols in food contact materials

6 Mar 2024

My suggestions for improvement of the BPA regulation are here listed since there are not enough characters allowed to include them here. CONCERNING THE PREAMBLES - preamble 3bis or 4bis - preamble 9 - preamble 10 - preamble 20. CONCERNING THE ARTICLES - artcicle 1 (a), (b) and (c) - article2 (b), - article 3 (1):,(2) (b) - article 4 (1) and (2) - article (5) (1) and 1 (c), - article 6 (1) - article 7 - article 8 - article 10 (5) Plus: eventual possible conflicts between this draft regulation and draft changes of reg 10/2011 recently discussed during last DG SANTE Meeting CONCERNING THE ANNEXES Annex II DETAILS More details can be found in the confidential annex.
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Response to Revision of the definition of engineered nanomaterial in food

1 Dec 2023

Why is the revision of the definition limited to "food" only? Why not also for "food contact materials and articles? Why, in order to avoid confusion, not apply the same definition for "food" and "food contact materials and articles"? .
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Response to Introducing new hazard classes–CLP revision

28 Sept 2022

After having participated in EFSA’s “oneEU2022” and in the “2022 4th Annual Forum on Endocrine Disruptors” I am convinced it is not only very important to know if a chemical is either ‘an endocrine disruptor with adverse effects on human health or with adverse effects on the environment’, and to regulate these substances accordingly. As Prof. Kortenkamp made clear during his presentation on endocrine disruptors disturbing the good functioning of the thyroid hormones, ED-regulation should be based on the correct scientific data. The introduction of new hazard classes as proposed should only be a first step to reduce the exposure of EU citizens to hazardous chemicals and to a better control of hazardous chemicals. After establish a legally binding hazard identification of endocrine disruptors under CLP the next step should be to apply it across all Union legislation. Here I wonder in particular how it will be applied to the 17 different categories of food contact materials (FCMs) that are mentioned in the present food contact framework regulation (EC) N° 1935/2004. Only 4 of these 17 categories of FCMs are regulated at EU-level. The other 14 categories are eventually and in a very diverging way regulated at national level, and in several cases dealt with y resolutions and guidelines of the Council of Europe/EDQM. How will EDCs be dealt with in food contact materials (FCMs) and articles (FCAS) that have not yet been regulated at EU-level such as paper and board, rubbers, coatings, adhesives, printing inks, silicones, waxes, textiles? Recent research has made it clear that substances and mixtures with endocrine disrupting properties pose a concern to public health and the environment. It has been proven that endocrine disruption can lead to certain disorders in humans, among others birth defects, developmental, reproductive, or neurodevelopmental disorders, cancer, diabetes and obesity, and that those disorders have a high and increasing incidence in both children and adults. Consequently, it seems clear that regulatory action should be taken.
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Response to Amendment of Regulation (EU) No 282/2008 on the recycling of plastic materials to be used as food contact materials

18 Jan 2022

In order to avoid confusion with ordinary recycled plastics and artisles made of them, I suggest the following change of definitions - "Recycled food contact plastic" or "recycled FC plastic" = Intermediate material from decontamination - "Recycled plastic food contact materials and articles" or "Recycled plastic FC materials and articles" = final food contact material or article
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