Ensuring safety in paper

Paper is no stranger to food. From tea bags to butter wrapping, and dry food cartons to liquid packaging board, there is a multitude of food related applications for paper and board products. The health and safety implications of food contact are of course taken very seriously by the paper industry. When it comes to consumer protection, the sector has cooperated at national government and EU level for many years and complies with EC regulation 1935/2004, which covers all materials that come in contact with food.

Some of those materials, such as cellulose film, plastics and ceramics, are subject to additional, material-specific legal measures that apply uniformly throughout the EU. As paper is considered a safe material, no harmonised measures have yet been put in place on a European level for paper and board.

In the absence of a harmonised EU measure for paper and board, some European Member States have taken action to regulate the paper and board nationally, with potentially significant undesirable effects to the sector. Furthermore, the unintended impression given to buyers is that compliance is less clear for paper and board than for other materials.

The food contact guideline
Against this background, the European paper packaging value chain has compiled a voluntary 'Industry Guideline for the Compliance of Paper and Board Materials and Articles for Food Contact' (the Industry Guideline).

The Confederation of European Paper Industries, CEPI, has also published Good Manufacturing Practice (GMP) for the industry. The Industry Guideline spells out the rules and the GMP describes a management system to be able to obey those rules.

The GMP is not an optional build-on to the Industry Guideline: current legislation requires all food contact materials to be manufactured in accordance with GMP. For companies in countries where industry-specific legislation already exists, the Industry Guideline will act as an additional source of information.

These paper and board guidelines should ideally be integrated into existing management systems of paper and board producers. For instance, the GMP assumes that operators have the ISO 9001 quality management system or equivalent in place. The Industry Guideline and GMP, however, focus on those aspects of quality assurance that ensure paper and board meets the quality standards appropriate to their intended use and will not endanger human health.

The Industry Guideline offers flexibility to allow for its use in different processes and materials and it facilitates straightforward auditing. It is based on realistic risk assessment and is specifically applicable to the manufacture of paper and board food contact material. There is no additional administrative burden for responsible producers. In some cases the Industry Guideline might even reduce the testing burden, as it contains rules that allow a reduction in testing frequency in certain areas.

For the moment, paper manufacturing companies representing more than half of the European production of packaging grades, and major converting companies covering a large share of the European paper-based packaging production, have implemented the Industry Guideline since 2010. Many other papermakers and converters are in the process of adopting it in their operations, and audits are also reported to have taken place.

A first revision of the guidelines included a few updates that were deemed important to food contact material handling due to:
- the coming into force of Commission Regulation on plastic materials and articles intended to come into contact with food, (EC) No 10/2011
- the update of German Recommendation on paper and board for food contact (BfR Rec. XXXVI)
- the concerns over the presence of mineral oil hydrocarbons in food

The Industry Guideline is a moving document, capable of being modified quickly in the light of scientific advances.

What will the European Commission do?
Whereas Europe's paper industry has found the experience gained with the Industry Guideline and the GMP very positive, it shares the views of other relevant industry sectors, in particular food producers in Europe, that producing a harmonised legal measure for paper and board in contact with food should nevertheless be a priority for the European Commission.

The Directorate General (DG) responsible for Health and Consumer Protection is about to launch a Roadmap on its next work items, which might include harmonising measures for paper and board for food contact at the EU level. It is likely that the Industry Guideline and the experience gained with it will serve as a basis for these measures.

www.cepi.org