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Normpack

Normpack

Supporting member companies for safer food contact materials and articles.

Lobbying Activity

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

8 Mar 2024

We, Normpack, thank you for the opportunity to respond to this consultation. Normpack is a Swedish business group of FCM actors active mainly on the Swedish market. The answers have been discussed in a working group of dedicated members. In principle, representatives from all steps in the FCM value chain have been a part of the group. From raw material suppliers to the food industry and food retail as well as food processing equipment manufacturer. As a general comment, we support the aim of the regulation to remove the exposure to and use of unwanted substances, based on scientific evidence. Our feedback is mainly structured relating to different types of FCM. However, some comments are more general affecting more than one type of FCM but are given under one of the headings. Repeated use products The rules applicable to plastic repeated use products that are not used in professional food production equipment need to be clarified. Examples of this type of products include dispenser boxes for confectionary in food retail, storage boxes used in households or restaurants, or food serving utensils. Does the requirement on declaration of compliance apply in the same way as for repeated use final food contact articles used in professional food production equipment? Which transitional rules will apply to this type of products? We suggest that paragraph 5, Article 10 is adjusted to clarify that repeated use products lawfully put on the market may be used until end of the normal lifespan, as outlined in the preamble, point 20. Food processing equipment When does the proposed requirements on information as stated in paragraph 4, Article 10, apply? When the proposed requirements entry into force or later? Producers of intermediate materials will have a similar requirement to inform downstream users at the latest nine months before the end of applicable transition period. A logical implementation might be that producers of final materials are required to inform their customers also at the earliest nine months before the applicable transition period, since they only are informed about the intermediate materials at that time. How shall migration from filtration membranes made from polysulphone resins be tested? The testing requirements in (EU) No 10/2011 does not stipulate testing conditions for flowing food as opposed to food in static contact with Food contact materials. There is a need for clarification or official interpretation of how the testing parameters as given in (EU) No 10/2011 should be applied for this specific application. Article 6 of the proposed regulation seem to only cover testing of FCM with BADGE. Please clarify who is responsible for removing repeat-use final food articles used in professional food production equipment from the market after the 10 years possible use. It would also be good to clarify the meaning of being on the market for this type of article. Paragraph 2, Article 4 stipulate possible use for bisphenols or derivatives of them, if an application is sent to the authority. In case (EC) No 1272/2008 is amended with new bisphenols during the transitional period of this upcoming bisphenol regulation, what transitional time should one consider? I.e. from when should the ban be considered then? Is it the transitional time mentioned in (EC) No 1272/2008 to be considered or should the transitional period in this upcoming bisphenol regulation apply? Paper and board materials and articles containing recycled materials. The given definition of a batch in paragraph 2 article 2, Point (f) emphasizes that a batch is a quantity of material that is produced using uniform production parameters at a certain manufacturing stage. This is not necessarily designated with a single production number. We therefore suggest that the definition of batch is adjusted to: batch means a quantity of material of the same quality and produced using uniform production parameters at a certain manufacturing stage, stored
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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

17 Jan 2022

The Business group Normpack (normpack.se) thank you for the opportunity to give feedback on the proposal on new EU legislation covering recycled plastics for food contact. We support the draft for a new regulation as it states that: • the ambiguity in today’s situation is resolved • there are clearer definitions of the different sequences in recycling • the clear ambition to potentially include all polymers • the possibility to test novel recycling technologies for innovation At the same time, we have these comments and proposals: Recital (5) Recital 5 states that” ...plastic waste should always be decontaminated...” If with the help of appropriate collection and sorting, the requirement of decontamination does not add increased level of protection for consumers, should the general requirement for decontamination be stated so strictly? It is rather the quality and purity of the material that an overall recycling technology can deliver that is important. We propose that, if a novel recycling technology involving collection and sorting can demonstrate the same level of safety, it should be possible to assess it under this Regulation, even if it is not primarily based on decontamination. We see this is discussed in recital 14, which we of course support. Recital (25) Recital 25 as well as article 6.3 state that waste collectors and pre-processors shall adopt a quality assurance system certified by an independent third party. Which standards for these quality assurance systems might be used? Please clarify with reference. Article 12 The requirement as written in Article 12(3)(c) becomes difficult to achieve and prove, which already the wording defines, with available techniques. The terms genotoxic and endocrine disrupting chemicals needs to be defined. The reference to article 13(4)(a) partly covers genotoxic substances and does not cover endocrine disrupting substances. Consider adding a text, possibly in the recitals, about being able to apply effect-based methods rather than methods for determining individual chemical substances, as a method for assessing recycled plastic materials. Article 13 Article 13(1)(c) requires the report to include a list of all chemical contaminants found in the plastic input and output. It would be helpful to specify the recommended analytical methods for measuring and identifying contaminants. Article 20 When shall these Guidelines be published? Article 27 The issue with official controls of recycling installations outside EU was briefly mentioned during the webinars 16 and 17 December, 2021. Consider updating Regulation (EU) 2017/625 to clarify how this new regulation on recycled plastics shall be controlled if applied partially outside the EU, also clarifying obligations for importers of these materials depending on stage in the production chain. Article 29 Please clarify the requirements for using the DoC template for converters. The title states that it is to be used for a material which in its entirety comes from a recycling process under this Regulation. However, it is also possible in the DoC template to state the highest proportion of recycled material in the finished material. This can seem confusing for a converter. Therefore, consider changing the requirements for a DoC in accordance with (EU) No 10/2011 at the same time. The DoC template for converters also states that substances with SML must be specified, however with the addition that some substances may lack an FCM number or SML limit value. Please clarify with examples or revise the parentheses. Is the intention also to require converters to state addition of for example polymer production aids or colorants? Documents are today increasingly signed digitally, and with that, no stamp is used. Consider revising the template accordingly.
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Response to Revision of EU rules on food contact materials

28 Jan 2021

We thank you for the opportunity to give feedback to the Inception Impact Assessment (IIA) on the revision of EU rules for food contact materials. Normpack is a Swedish based business group since 40 years. Our 180 member companies cover all sectors of the FCM industry, with a majority being small and medium sized converters and producers of packaging solutions. Please see the attached document for our feedback.
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