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Is it necessary to test for sulphites in tissue paper?


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#1 Maltus

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Posted 30 June 2016 - 08:28 AM

Yesterday, our client (a tissue paper making company) passed his ISO 22000 Packaging audit. 

 

They use sodium metabilsulfite to neutralize chlorine added during paper production procees. Auditor asked them to perform some lab analysis in finished product (napkins), so that they could check that the level of sulphites is under 10 ppm.

 

Actually, I'm still shocked. I thought that regulation (1169/2001) applies only to food labelling. Anyone has had any ploblem with allergens in food contact materials?


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#2 Charles.C

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Posted 01 July 2016 - 04:46 AM

Yesterday, our client (a tissue paper making company) passed his ISO 22000 Packaging audit. 

 

They use sodium metabilsulfite to neutralize chlorine added during paper production procees. Auditor asked them to perform some lab analysis in finished product (napkins), so that they could check that the level of sulphites is under 10 ppm.

 

Actually, I'm still shocked. I thought that regulation (1169/2001) applies only to food labelling. Anyone has had any ploblem with allergens in food contact materials?

 

Hi Maltus,

 

I deduce that the implied  auditorial risk to the consumer is related to a potential cross-contamination from tissue “packaging” to consumed food ? Realistic ? (presumably relates to designated function of tissue).

 

I deduce the auditor suggested that Reg. 1169/2001 could be consequentially implicated.

 

This Reg. is long and highly tortuous.

 

I suppose that, depending on the specifics, ie intended usage of the tissue, clause 1©, Pg 28 might be involved (“stretched”) in combination with Annex II which contains  -

12.  Sulphur  dioxide  and  sulphites  at  concentrations  of  more  than  10 mg/kg  or  10 mg/litre  in  terms  of  the  total  SO2 which  are  to  be  calculated  for  products  as  proposed  ready  for  consumption  or  as  reconstituted  according  to  the instructions  of  the  manufacturers;

Just speculating. Not a packaging person. :smile:


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Kind Regards,

 

Charles.C


#3 Sharon (Dewsbury)

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Posted 13 July 2016 - 02:02 PM

Hi all, I work in packaging and I suspect that the auditor was getting at MIGRATION contamination from packaging. Be the contaminant an allergen or some other substance regulation (EC) No 1935/2004 is relevant .

see item 3. Contact packaging or material must be sufficiently inert to preclude substances from being transferred to food in quantities large enough to endanger human health. So I guess you need to prove that to be true of your paper either by maths or analysis.

RAPRA & PRIA are 2 companies I have used previously for this analysis. They may be able to advise. 

Regards
Sharon

 

Extract below

REGULATION (EC) No 1935/2004 OF THE EUROPEAN PARLIAMENT AND OF THE COUNCIL

of 27 October 2004

on materials and articles intended to come into contact with food and repealing Directives 80/590/EEC and 89/109/EEC

THE EUROPEAN PARLIAMENT AND THE COUNCIL OF THE EUROPEAN UNION,

Having regard to the Treaty establishing the European Community, and in particular Article 95 thereof,

Having regard to the proposal from the Commission,

Having regard to the opinion of the European Economic and Social Committee (1),

Acting in accordance with the procedure laid down in Article 251 of the Treaty (2),

Whereas:

(1)

Council Directive 89/109/EEC of 21 December 1988 on the approximation of the laws of the Member States relating to materials and articles intended to come into contact with foodstuffs (3) established general principles for eliminating the differences between the laws of the Member States as regards those materials and articles and provided for the adoption of implementing directives concerning specific groups of materials and articles (specific directives). This approach was successful and should be continued.

(2)

The specific directives adopted under Directive 89/109/EEC in general contain provisions which leave little room for the exercise of discretion by the Member States in their transposition besides being subject to frequent amendments required to adapt them rapidly to technological progress. It should therefore be possible for such measures to take the form of regulations or decisions. At the same time it is appropriate to include a number of additional subjects. Directive 89/109/EEC should therefore be replaced.

(3)

The principle underlying this Regulation is that any material or article intended to come into contact directly or indirectly with food must be sufficiently inert to preclude substances from being transferred to food in quantities large enough to endanger human health or to bring about an unacceptable change in the composition of the food or a deterioration in its organoleptic properties.

 


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