Current food safety legislation includes a patchwork of regulations, and their application to packaging adhesives is not always straight forward. Below is a useful introduction to key regulations, as well as an explanation of their relevance to adhesives.
Our regulatory experts have a deep knowledge of local legislation that, when shared with our global network, leads to a more complete understanding of food safe packaging and the role of adhesives. For more information on food safe packaging legislation around the world, click here.
European Union (EU) Food Safety Laws One of the cornerstone pieces of EU legislation is Framework Regulation (EC) No. 1935/2004. It sets out general principles with which all food contact materials and articles need to comply. Its aim is to ensure that food contact materials do not endanger human health, change the composition of the food or degrade its sensory characteristics, such as taste or smell.
In addition, all food contact materials should be manufactured in accordance with Regulation (EC) No. 2023/2006 covering good manufacturing practice (GMP) for food contact materials and articles.
Some specific materials, such as plastics, ceramics and regenerated cellulose film, have their own harmonized European regulation. The harmonized European Plastics Regulation (EU) No. 10/2011 includes a list of more than 1,000 substances authorized for use in the EU. However, many materials, such as adhesives, paper and board, inks, coatings, and rubbers, are not covered by a harmonized European regulation today. In this case, member states may adopt national regulations.
Germany, Spain, Italy, The Netherlands and others have implemented their own legislation on food contact materials, which cover a range of materials not subject to European harmonized legislation. In some cases, adhesives are included. The US Food and Drug Administration (FDA) has legislation regulating adhesives in food contact materials, while China, India and MERCOSUR (Argentina, Brazil, Paraguay and Uruguay) are enhancing their legislation, with possible implications for adhesives.
In the EU, adhesives are subject to the Framework Regulation (EC) No. 1935/2004. However, because they are not covered by a European harmonized regulation, stakeholders in the food industry often turn to the Plastics Regulation, which includes a list of authorized substances. This list is the main regulatory reference used by adhesives suppliers. Alternatively, reference may be made to the opinions of the European Food Safety Authority (EFSA), to Resolutions of the Council of Europe, to national legislation, and even to non-European legislation for a necessary risk assessment. This is not an ideal situation since the varying requirements can create complications for adhesive suppliers and their customers.
Industry associations often provide guidance for non-harmonized materials. The Association of the European Adhesive and Sealant Industry (FEICA), with support from its member companies including H.B. Fuller, has produced a range of useful guidance documents on adhesives in food contact materials to help support food industry stakeholders. These can be found here.
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