Food Contact Legislation

Helping you to follow legal requirements

A rising number of regulations and the strong demand to apply Good Manufacturing Practices (GMP) are building the framework for the design and production of food safe packaging and food contact materials.

With regard to food safety, the focus is on minimizing risks for human health caused by substances intentionally (IAS) or non-intentionally (NIAS) added during the various production stages. Producers of food products and their suppliers have to assure that for approved substances regulatory thresholds are not exceeded and that non-approved substances such as NIAS do not constitute a health risk.

Henkel Adhesive Technologies is providing product solutions and services that help you follow the respective legal requirements on safety of food contact materials.

Framework Regulation

The regulation (EC) No 1935/2004 contains general requirements but no precise instructions on how to demonstrate compliance. Article 3 of the European Regulation (EC) No 1935/2004 states that such food contact materials and articles shall not transfer their constituents into food in a quantity that could:

  • Endanger human health
  • Bring about an unacceptable change in the composition of the food
  • Bring about deterioration in the organoleptic characteristics of the food

Adhesives have to be understood as a constituent of the food contact material. In addition, several EU member states have additional national regulations that apply to packaging materials and articles intended for food contact. Consequently, a risk assessment concerning migration and impact on the packed foodstuff has to be performed for each application.

Find more information on the website of EUR-Lex

GMP Regulation

Article 3 of EU Regulation (EC) No 1935/2004 and articles 5-7 of EU Regulation (EC) No 2023/2006 stipulate the implementation of Good Manufacturing Practices (GMP) in all operations producing packaging for food applications. GMP aims to ensure that products are consistently produced and controlled to the quality standards appropriate to their intended use.

Materials that are produced in accordance with GMP support producers of food packaging and food contact materials in their commitment to only market products that comply entirely with the European requirements for food contact materials. The European Adhesive Association FEICA has developed a GMP guideline that covers the manufacturing process of all adhesives and coatings used in the production of food contact materials with regard to the handling of hazards and food safety.

Find more information on the website of FEICA

Plastics Regulation

Besides the Framework Regulation, there are some material-specific regulations in place. The Plastics Regulation (EU) No 10/2011 is a specific measure for plastics in food contact. It does not apply to adhesives and coatings as it only governs plastic layers in multi-material-layers. Nevertheless, the Plastics Regulation lists specific migration limits (SML) for individual substances that have to be taken into account, with many of these also used in adhesives. Since these restrictions are based on toxicological data, no health risk is to be expected as long as they are not exceeded.

Find more information on the website of EUR-Lex  

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