Food Contact Materials Regulation (EC) 1935/2004
Hi
One of our prospect customer is asking for Compliance in EC 1935/2004, if our canned non-alcoholic beverage product complies. Is the can manufacturer FC certificate sufficient enough to comply?
Depends what the FC certificate actually says - if it is clear that it includes compliance with Regulation (EC) 1935/2004 then yes, it should be sufficient (obviously assuming that the supplier of the cans has the data to back up the assertion).
If it's a more generic statement that the cans are suitable for food contact applications then I'd be inclined to ask the manufacturer to provide further detail, as food contact requirements aren't identical globally.
It may be the case that they don't know / haven't checked, given that it may be of limited relevance for the local market, in which case you may need to source something specific to suit the requirement.
Dear Ives101,
for me there are some informations missing. In general the answer is yes, but....
How do you define "certificate" = declaration of conformity?
There are clear requirements for a decaration of conformity depending on the material (e.g. plastics) and the product which influences migration.
What is the FCM (metal)? Or is the material coated? What material(s) are exposed to the product?
According to Chapter 4 of the Guidelines on Metals and Alloys of the Council of Europe, materials and articles made of metal and alloys should be accompanied by a declaration of conformity. Please note that this is a recommendation and is therefore not legally binding. It is therefore not associated with a traffic ban in Germany. (for other countries I don't know, because we don't use metal packagings).
To provide the correct information the supplier of the packaging material should know the properties of the product packed.
This is my "European view" on the regulation not knowing the gap to Australian legislation for cans.
1935/2004 is the framework regulation for food contact materials. Underneath this, there are a number of other more specific regulations which must be met before you can say that you comply with 1935/2004.
For cans these will be the GMP regs 2023/2006 as stated earlier, plus regulations relating to the can coating. This is likely to be an epoxy type coating which means that the relevant regulation is EC1895/2005. Just to be even more of a pain, many epoxy coatings contain BPA and there is an additional regulation EC2028/213 relating to this giving maximum levels.
All of these must be met before your supplier can say that their product meets 1935/2004.
BPA is banned in some EU countries for food contact materials and the way things look it will become a total EU ban in the next year or so. I would ask your supplier for Declarations of Compliance for the above regulations and would seriously look at confirmation that they are BPA free
Thanks Foodworker for detailed guidance.
Cheers