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On April 10th, EURACTIV and the European Container Glass Federation (FEVE) co-hosted the workshop “Safe and
Circular: Making Food Contact Material Work for Consumers and the Environment”. Speakers included the
Director of Food and Feed Safety, Innovation (DG SANTE), Food Packaging Forum’s Managing Director, a Policy
Analyst from the Institute for European Environmental Policy (IEEP) and a representative of FEVE. This event
served to address the future of Food Contact Materials (FCM) in regards to the goals brought forward by the
Circular Economy Strategy.

The European Commission defines Food Contact Materials as materials that are intended to be
brought into contact with food, are already in contact with food, or can reasonably be brought into
contact with food or transfer their constituents to the food under normal or foreseeable use. This
includes direct or indirect contact. Examples include containers for transporting food, machinery to
process food, packaging materials, kitchenware and tableware.

A large majority of the above listed FCMs are made from one material, plastic. To further address
plastic waste within the Circular Economy Strategy, the Commission put forth the Plastic Strategy. A
great emphasis has been put on the EU’s need to increase its recycling efforts by 2030; however, this
could have an impact on the safety of FCMs. The speakers at the event aimed to answer, among
others, to the following questions:

 Should the FCM legislation be revised?

 Are there proper risk assessment methods in place to ensure that increasing the recycled
content of packaging will also guarantee safety and quality?
 How can waste collection and recycling systems be improved to ensure more traceability for
FCMs? What role for traceability and labelling?
 Should factors such as the “quality” and “duration” of FCMs and food products be considered
when regulating FCMs?
 What role for innovation in finding new environmentally friendly solutions that can also
protect consumers?

An area of great concern addressed during the workshop was the need to have a closed loop-
recycling stream, which would solely be used for FCMs. Current plastic waste management
regulations lack clarity regarding the separation and collection of plastic waste intended to be
recycled. These plastic wastes are often recycled by small regional facilities, which lack the
knowledge needed to safely recycle plastic coming from different waste streams. Ms Sabine Jülicher,
Director of Food and Feed Safety and Innovation at DG SANTE, stressed the need for more
knowledge and information on how to safely recycle FCMs. This sentiment was echoed by multiple
other speakers and stakeholders present during the workshop.

Ms Jane Muncke from the Food Packaging Forum indicated that there are two classes of recyclable
material: permanent materials, which in general contain little to no chemical substances, and non-
permanent materials such as paper and plastic. Non-permanent materials contain a large amount of
chemicals, as there are currently over 8,000 chemical substances approved for use in the production
of FCMs. However, the amount of chemicals accepted for use in FCMs is only the tip of the iceberg,

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since the most concerning safety issue associated with recycled plastic is the presence of Non-
Intentionally Added Chemicals (NIAS). NIAS are chemical compounds that are present in a material
without being added for a technical reason during the production process. NIAS contamination can
originate from multiple sources (e.g. impurities, misuse, improper separation of materials, legacy
substances or cross-contamination during waste collection), and is generally not known by the
consumer. A practical example of this type of contamination is the introduction of laundry chemicals
in food grade plastics, due to the mix recycling stream of laundry detergent contaminated plastic
with food grade plastic.

Although all FCMs are subject to chemical migration and leakage, NIAS are more likely to migrate
from the packaging to the food and the environment due to their small size. Therefore, without the
proper regulation in place, the recycling goals outlined in the Plastic Strategy could drastically
increase the number of NIAS found in FCMs.

In addition to NIAS, micro-plastics have also proven to be a very important safety and environmental
problem. Micro-plastics are small (below 5mm in size) fragments of plastic that leak into the sea, the
atmosphere and the food. Micro-plastics are not only accidentally created through plastic
degradation but are also produced at a rate of 75,000 and 300,000 tonnes each year in the EU. There
are indisputable proofs that micro-plastics are very harmful to the environment, to the point that
countries such as the United States and Canada have already taken steps to ban them and additional
regulations and measures should be taken in the EU. At the very least, experts advise that more
research and risk assessment should be carried out micro-plastics present in FCMs, as there is little to
no information regarding the effects of micro-plastic on the human health.

Moreover, the existing testing parameters regarding the risk assessment of FCMs should be revisited
and supplemented. Currently, a Life Cycle Analysis (LCA) is carried out on FCMs, although experts are
widely critical of LCA as it does not take into account human health impact and puts a large emphasis
on GHG emission, encouraging producers to create increasingly complicated FCMs. These complex
FCMs are then impossible to recycle in a way in which no NIAS will enter the recycling cycle.

Mr Jean Pierre Schweitzer from the Institute for European Environmental Policy (IEEP), which on the
day of the event had come out with a plastic packaging and food waste report entitled “Unwrapped –
How Throwaway Plastic is Failing to Solve Europe’s Food Waste Problem”, discussed several
problems, solutions and recommendations regarding making FCMs safer and more circular. The
report drew a correlation between the increase in food packaging waste and the increase in food
waste, contradicting the view of many consumers and industry professionals who associate an
increase in food packaging with an increase in food safety, quality and shelf-life. In addition to that,
the IEEP outlined the importance of increasing public awareness regarding the damage done by
single-use plastic, and suggested a few possible solutions to the excess of food packaging currently
used in the food industry, including shifting to minimal or zero food packaging and shorter supply
chains. IEEP also called for the reduction of non-permanent materials use and supported the
implementation of Green Public Procurement (GPP) efforts. GPP is a voluntary instrument, which can
help stimulate a critical mass of demand for more sustainable goods and services which otherwise
would be difficult to get into the market. The European Commission and a number of European
countries have developed guidance in this area, in the form of national GPP criteria. Such schemes
have been in place in many Member States for many years and have been proven successful.
Examples of GPP include waste-free food retailers and glass bottle returning containers.

A large emphasis was put on the need to find alternatives for plastic packaging in the context of a
circular economy. However, it is important to note that many plastic alternatives currently present in
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the market are no better and sometimes worse than plastic. For example, biodegradable plastic only
proves to be biodegradable under strict and exact conditions. However, the lack of proper labelling
causes consumers to improperly use the material, which makes the plastic not treatable and
recyclable. In addition, biodegradable plastics can aggravate plastic leakage and create problems for
mechanical recycling, while plastics that are labelled 'compostable' are often not suitable for home
composting. If compostable and conventional plastics are mixed in the recycling process, it may
affect the quality of the resulting recycles. Another example is oxo-degradable plastic, a type of
biodegradable plastic that has been found to offer no proven environmental advantage over
conventional plastics, as its rapid fragmentation into micro-plastics causes severe environmental

FEVE advanced that when speaking of FCMs, quality and safety should have an equivalent
definition. The food industry fears recycled plastic, due to its perceived lower quality and the fear of
incidental combinations that may cause NIAS contamination. Such incidental contaminants affect
both the quality and safety of recycled FCMs. However, since there are currently permanent
materials that do not lose quality with recycling – such as glass – FEVE believes that the food industry
and consumers should favour the use of such permanent material, when possible. This would cut
down on negative environmental and health effects, while also helping attain circularity within FCMs
at a faster pace.

In conclusion, FCM waste legislation should be revised to safely move forward on the 2030 recycling
goals outlined in the Plastic Strategy. Better risk assessment and testing should be put in place to
reduce safety risks brought on by NIAS and micro-plastics leakage from FCMs to our food. Consumers
and industry will need to change their use of FCMs and really address the problem of plastic waste.
Permanent materials, GPP and shorter supply chains are all suggested strategies to invest on and
implement to attain a full circularity in the food industry.

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