Food contact materials are sometimes subject to rigorous checks in the EU because market surveillance authorities want to ensure that the population is not exposed to harmful chemicals and other dangers when storing or consuming food and beverages. This is fair enough given the sensitive nature of these products!

We wanted to find out what problems were commonly found in food contact materials and products so we researched incidents in the EU among food contact materials using the Rapid Alert System for Food and Feed (RASFF) for 6 months from late 2023 to around April 2024. The findings provide some helpful insights about which products did not comply with safety regulations if you’re an importer of food contact products.

 

 

What kind of food contact products are being imported into the EU?

food contact materials

There are a huge number of different types of food contact products, but to give you an idea, here’s a non-exhaustive list of those included in our research:

  • Silicone cookware and tools (plates, etc)
  • Baby bottle teats
  • Cutlery and kitchen tools
  • Bamboo fiber products
  • Pizza boxes
  • Melamine kitchenware
  • PP boxes and bottles
  • Dried goods packaging
  • Ceramics
  • Paper plates
  • Napkins
  • Nylon gloves

 

What hazardous substances were found, and in which products?

We categorized the products and listed the hazardous substances found. Typically these would be hazardous substances such as those restricted by REACH, RoHS, and POP tests, for example. Use this information to see what kinds of substances you should be vigilant for if you are also importing that type of product into the EU.

food contact materials hazardous substances eu 2023 1food contact materials hazardous substances eu 2023 3food contact materials hazardous substances eu 2023 4

Let’s break down some of the substances found and why they’re harmful:

  • Lead: Proven to cause severe neurological damage and cognitive impairment, especially in children.
  • Cadmium: Causes kidney damage and bone fractures, and is a known carcinogen.
  • Aluminum: Linked to neurotoxicity and diseases like Alzheimer’s.
  • Lithium: Affects the nervous system and kidneys.
  • Cobalt: Causes respiratory issues and skin dermatitis, and may be carcinogenic.
  • Manganese: Causes neurological problems, including Parkinson-like symptoms.
  • Phthalates: Disrupt endocrine functions, and can cause reproductive and developmental issues.
  • Aromatic amines: Known carcinogens that can cause bladder cancer and other diseases.
  • BPAs: Cause hormonal imbalances and an increased risk of reproductive disorders, cancers, and other health issues.
  • VOCs: Responsible for respiratory problems and skin irritation, and can cause liver and kidney damage or cancers.

Reading these examples, you can now see why weeding out food contact products with these issues is important for market surveillance authorities. Worryingly, pizza boxes, plastic containers, and kitchen utensils were found to include harmful substances in many cases.

 

Where did the problem products come from?

In the period researched of approximately 6 months between late 2023 and spring 2024, the problem products flagged for being non-compliant largely came from China and Turkey, with Spain and Italy further behind.

hazardous food contact products countries of origin 2023 2024

This perhaps won’t come as much of a surprise, but it serves as a reminder to be extra vigilant when purchasing from China and Turkey.

 

What actions were taken on the non-compliant products?

The authorities took various actions, ranging from nothing at all to destroying the offending products.

actions taken on hazardous food contact materials

Reinforced checking, informing the consignor, and detaining them are the most common actions, but withdrawal from the market and destruction were also commonly taken.

 

What are the related regulations/directives?

These products fall under the EU food contact regulation framework.

However, this is not sufficient, as the EU countries haven’t fully harmonized their requirements. A product to be sold in 10 EU countries has to satisfy the regulatory requirements of those 10 countries…

 

General advice to reduce such risks

We know that China and Turkey are hotspots for non-compliance on this topic, so it’s a must-do to ensure that suppliers understand what you cannot accept, and that you are arranging product testing. Make sure you work with suppliers who are aware of the regulations. Perhaps they can show you proof that they have made compliant products in the past?

Food contact material products can be checked by market surveillance authorities, especially as some children’s products like feeding bottles are included in this category. Sometimes an NGO also picks some products and has them tested, if they are digging around your brand for trouble…

Hazardous substances will commonly be found in regular REACH, RoHS, and POP testing, but the authorized limit may not be the same. So, as an importer you may wisely choose to do a bit of research and then get the products tested to some of those standards in a lab before shipping them to the EU.

Even if your supplier runs their own lab tests and provides you with a report, unless they’re proven to be capable and trustworthy beyond doubt you should run your own laboratory tests, at least initially.

 

Disclaimer

We at Sofeast are not lawyers. What we wrote above is based only on our understanding of the regulatory requirements. We do not present this information as a basis for you to make decisions, and we do not accept any liability if you do so. Please consult a lawyer before taking action.

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