The regulatory landscape of materials in contact with food is complex and constantly evolving.
We have interviewed Luca Foltran, UL’s Food Contact Materials Subject Matter Expert to clarify your doubts and to reply to relevant questions in this field for the European market.
To learn more about these topics, we invite you to join our complimentary UL Food Contact Materials webinar series for insights on US, EU and Asia markets access. Register HERE.
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Question: In which cases the use of the food symbol (glass and fork) is mandatory and where should it be placed?
Luca: Each object intended to come in contact with food — but not yet in contact with the food product when it is placed on the market — must include information that specifies its food suitability. This information is represented by:
- the food symbol
- the wording “for contact with food”
- the specific indication of the use of the article (e.g. coffee machine, bottle for wine, spoon for soup).
This information must be visible when consumers are buyıng the article in the point of sale and may be present on the article itself, on its packaging or on tags which must be clearly visible to buyers and located in the immediate vicinity.
However, the possibility to use a tag is only allowed if it’s not possible to affix this information of specific labels due to technical reasons, neither in the processing nor in the marketing phase.
Question: Should the interior of a refrigerator be considered as a material in contact with food?
Luca: The European Regulation 1935⁄2004 establishes that the articles (or components) for which contact with food products is reasonably expected are to be considered “materials in contact with food”. Specific parts of a refrigerator certainly fall into this situation because the consumer can store food in direct contact.
To establish which areas of the appliance fall within the definition of “materials in contact with food”, a specific risk assessment is required on the refrigerator.
Question: If metals are not regulated in Germany while there is a law in Italy, is a German manufacturer no longer facilitated in marketing catering equipment?
Luca: It should be considered that the European Regulation 1935⁄2004 is valid throughout Europe and those who market materials in contact with food must respond to this Regulation. The food suitability of the equipment must be demonstrated both by those who produce in Italy and by those who produce in Germany, and the absence of laws regulating metals on the German territory does not justify a possible absence of supportive documentation (including test reports). This means that even those who manufacture in Germany will have to proceed with appropriate assessments and tests to demonstrate the sufficient inertia of the equipment towards the food.
Question: How often should migration tests be carried out on the finished product in the “materials in contact with food” context?
Luca: The law does not define “deadlines” for migration tests and compliance documentations: it falls under the responsibility of those who market the “materials in contact with food” to ensure that documents are sufficiently updated. If there are changes in the level of materials used to produce the article, changes in the production process, or legislative updates with direct impact on the specific article, new assessments and testing must be performed.
Question: We often hear about “Declaration of Conformity” to be drawn up for materials in contact with food, in order to demonstrate their food suitability. Is there a declaration template proposed by law?
Luca: The law establishes that every item or equipment must be accompanied by a written declaration that certifies its compliance with current regulations. This is therefore a mandatory document but for which the law does not provide a specific template. Based on the type of article, the materials involved and the foreseeable uses, UL is able to establish the structure of this declaration and how it must be drawn up to comply with the obligations set out in the European Regulation 1935 ⁄ 2004.
Question: Do professional catering equipment such as fryers, ice breakers, planetary mixers fall within the “materials in contact with food”? Are there distinctions from the domestic environment?
Luca: Professional catering equipment, for which contact with food-use substances is expected during normal use, falls within the scope of the European Regulation 1935⁄2004 and their food suitability must therefore be demonstrated.
There are no particular differences compared to the process envisaged for household items. The identification of the components that come into contact with food, the specific temperatures and contact times are determined through close collaboration and exchange of information between the manufacturer and the certification body. UL can support in this area even to obtain the appropriate documentation from the suppliers of the different components that make up the machine.
Who is Luca Foltran?
For over 15 years, Luca has been dealing with evaluations of packaging and materials intended to come into contact with food substances and with the related Italian, European and international legislations.
Luca participates in working groups for materials in contact with food and he is a member of the Italian Food Contact Expert association, intended to promote and develop knowledge in the food sector.
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