Companies that produce foodstuffs ensure food safety of the product in order to prevent consumers from getting sick. The European Union imposes the regulations (EUR-Lex 32006R2023 and EUR-Lex 32004R1935) for packaging, packaging material and other objects that affect food directly or indirectly. They include rules on how to meet standards, prohibited materials, identification of “food-safe” materials and traceability of steps in the production process. Member states and countries that want to enter into free trade with EU members in the Schengen region are required to organise their national legislation as such that it meets these guidelines. The European Food Safety Association (EFSA) is a European Union agency that provides independent scientific recommendations with regard to food safety to support EU legislation and policy.
When it comes to food packaging, several aspects are important for guaranteeing food safety. Legislation prescribes what requirements foodstuffs and other products must meet. This involves the product’s consumer safety and the responsibility of the manufacturer in that regard. An example is the interaction that can occur between the product and the packaging, which may involve the migration of substances from or through the packaging into the product. Legal limits were set to mitigate this effect.
Food contact materials are all materials that come into direct contact with foodstuffs, such as packaging materials, machines for the production of food and kitchen appliances. There are several ways in which contaminations may migrate to foodstuffs from these materials. This is why food contact materials are subject to stringent requirements in order to guarantee food safety. Requirements apply to the materials at the European level; member states translate these requirements into lists of accepted materials for food contact.
When it comes to increasing the sustainability of packaging, the following applies with regard to food safety: “whatever you put in, must come out”. A lot of packaging is collected, sorted and recycled after use. The substances in or on the packaging must be extracted during the recycling process. This may involve substances used in ink and filler material such as mineral oils. These substances may pose health threats and must be prevented from getting in contact with foodstuffs once recycled.
- Mineral oils (MOAH and MOSH)
Many foodstuffs come in paper and cardboard packaging, often made of recycled paper. This kind of packaging may contain contaminants, for example from mineral oils that migrated from newspaper ink. These contaminants are either aromatic hydrocarbons (MOAHs) or saturated hydrocarbons (MOSH) from mineral oils. There are several ways in which contaminants found in packaging materials can migrate to food products. One example is the presence of mineral oils in packaging materials made from recycled paper and cardboard. These mineral oils can also end up in food products in other ways, e.g. through the use of lubricating oil and hydraulic oils in harvesting and production machinery.
- Bisphenol A (BPA)
Bisphenol A (BPA) is applied, amongst others, in rigid plastic food packaging and coatings. Limits in BPA migration from food contact materials into the food, for example from packaging, are intended to mitigate the risk of high levels of exposure. The presence of BPA must be avoided when applying recycled materials.
Food safety and recycled materials
- Metal and glass
Food contact is not usually a problem when it comes to recycled metal and glass because processing temperatures are high (over 1,400 °C), which causes ink and glue to burn up. In addition, glass is inert which means no hazardous substances can migrate into the material.
- Paper and cardboard
Paper and cardboard are not heated. Instead, the fibres are de-inked where possible in order to reduce any substances which are present. This is difficult, as proven by the fact that mineral oils are found in products packaged in recycled paper and cardboard.
Recycled material in plastic packaging is subject to migration limits just like all food contact materials. In addition, EFSA has drafted the following guidelines:
- 95% of recycled PET (rPET) must have been extracted from food packaging to prevent the recyclate from containing hazardous substances. Research by the Netherlands Institute for Sustainable Packaging (KIDV) demonstrates that a lot of chain parties interpret this EFSA guideline percentage as binding and more strict than legally required. This guideline percentage can be deviated from if the manufacturer is able to demonstrate that the features of the recyclate and the manufacturer’s process meet the food safety prescriptions. At the moment, rPET from deposit bottles is primarily applied in food contact packaging since its food application has been demonstrated. In the case of PET packaging of mixed plastic packaging material, it needs to be taken into account that an increasing amount of PET packaging is used for non-food applications such as soap products.
- The EFSA recommendation is more limiting for recycled HDPE (rHDPE) than for rPET. According to a 2015 authorisation recommendation, no more than 30% of food packaging materials may consist of rHDPE. 99% Of the rHDPE must have been sourced from food packaging. This is due to the fact that HDPE is used for non-food packaging more often than PET which means it creates higher safety risks. ‘Closed-loop’ collection and recycling systems of PP and HDPE are allowed for food packaging as long as the original packaging met the food safety requirements. Great Britain executed a project where HDPE milk packaging could be distinguished or collected separately due to its shape. This allowed it to be recycled and reapplied in a food packaging product.
Situation in various countries
The Netherlands applies positive lists for substances in plastic, paper, cardboard, coatings, rubber, metal, wood and cork, regenerated cellulose and textile. Click here for information on approved substances by the National Institute for Public Health and the Environment (RIVM).
The packaging and the product
Sustainable product-packaging combinations are always the result of the right combination of product properties and packaging properties. When making a packaging more sustainable, it is important to first prevent product loss, avoid product wastage, and guarantee the safety of the user and the environment. Most of the environmental impact of a product-packaging combination is caused by the product itself; around 10% of the total environmental impact is caused by the packaging. Once all these aspects have been optimally safeguarded, you can explore options to make the packaging more sustainable. Examples include reducing the amount of material used or using sustainable material applications, without compromising the packaging functionality.
Improving the sustainability of packaging is more than simply reducing the amount of material used. The following measures will make packaging more sustainable as well:
- preventing the wastage of raw materials during its production;
- tailoring the packaging to fit the product that will be transported in it;
- using as many renewable or recycled materials as possible for its production;
- using sustainable technologies and energy during its production;
- setting up the logistical process as efficiently as possible and avoiding the transport of empty air.
That is why it is important to take each of the following aspects into consideration when developing a sustainable packaging solution: product protection, food safety, effective product usage en measuring sustainability.
Regulation EC 1935/2004 on food contact materials
Paper – published by European Parliament and of the Council
EFSA guidelines ‘plastics and plastic recycling’
Paper – published by European Food Safety Authority
Fact Sheet Bisfenol A (BPA) in packaging
Paper – published by Netherlands Institute for Sustainable Packaging
Fact Sheet mineral oils (MOAH and MOSH) in recycled paper
Paper – published by Netherlands Institute for Sustainable Packaging