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Legal Requirements for Plastics


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Selvin Santos

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Posted 17 September 2020 - 05:54 PM

Hello, 
 
I would like you to help me with your experience in the following:
 
To comply with the legal requirements on "Plastic Packaging" such as PET and HDPE, I have normally always considered (depending on the use) the following:
 
1.- Migration Analysis (Globla and/or specific)
2.- Heavy Metal. 
 
Sometimes due to the type of packaging and customer requests I have also done analysis of phthalates and bisphenol a. 
 
However, I would like to know if in your experience any type of analysis should be considered. Generally the product is only sold in the United States and Europe (Its honey) 
 
I hope I have been clear, I will look forward for your comments.  
 
Thanks !!
 
:) 


pHruit

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Posted 18 September 2020 - 09:17 AM

For EU purposes, the migration limits are defined against specific "simulants", which are chosen to mimic the characteristics of different types of food.

Packaging for honey looks like the migration testing should be conducted with Simulant A, an ethanol solution at a concentration of 10%v/v - see Table 2 of Annex III of Regulation (EU) 10/2011: https://eur-lex.euro...ELEX:32011R0010

Some of the requirements of this regulation are probably better addressed via confirmation from your packaging supplier than via testing, as it sets out a so-called "Union list" of authorised substances for use in plastic materials for food packaging, and whilst you could potentially verify this by analysis, it is likely to be far more efficient to ask your packaging supplier to provide positive confirmation that the materials they supply are compliant with this list, and indeed with the general requirements of this regulation and of Regulation (EC) 1935/2004, which is the broader regulation on food contact materials (10/2011 specifically relates to plastics).



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Selvin Santos

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Posted 18 September 2020 - 03:04 PM

For EU purposes, the migration limits are defined against specific "simulants", which are chosen to mimic the characteristics of different types of food.

Packaging for honey looks like the migration testing should be conducted with Simulant A, an ethanol solution at a concentration of 10%v/v - see Table 2 of Annex III of Regulation (EU) 10/2011: https://eur-lex.euro...ELEX:32011R0010

Some of the requirements of this regulation are probably better addressed via confirmation from your packaging supplier than via testing, as it sets out a so-called "Union list" of authorised substances for use in plastic materials for food packaging, and whilst you could potentially verify this by analysis, it is likely to be far more efficient to ask your packaging supplier to provide positive confirmation that the materials they supply are compliant with this list, and indeed with the general requirements of this regulation and of Regulation (EC) 1935/2004, which is the broader regulation on food contact materials (10/2011 specifically relates to plastics).

 

Thanks for the information. 
 
I guess I wasn't so wrong about what I'm doing. 
 
I share with you what I have done, the only thing I don't know is if the same regulation applies to them, depending on the type of raw material. 

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pHruit

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Posted 18 September 2020 - 03:18 PM


I share with you what I have done, the only thing I don't know is if the same regulation applies to them, depending on the type of raw material. 

 

Do you mean in terms of plastic/polymer (or other) packaging raw material, or the food raw material that is placed in the packaging?

 

 

Your list looks pretty good, the only two potential points to note are:

  • 1935/2004 does apply to plastic material in addition to 10/2011
  • Bisphenol A is currently sat in a slightly odd position, as it's still permissible in the EU (with exceptions around e.g. bottles for babies) with a relatively recently reduce migration limit, but France has banned it. This is a bit problematic in terms of how EU law is supposed to work! Nonetheless it remains somewhat vilified in Europe, so if you can avoid packaging that uses it then it's likely to be the most popular approach with customers here ;)


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Selvin Santos

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Posted 18 September 2020 - 03:51 PM

 

Do you mean in terms of plastic/polymer (or other) packaging raw material, or the food raw material that is placed in the packaging?

 

((Yes))

 

 

Your list looks pretty good, the only two potential points to note are:

  • 1935/2004 does apply to plastic material in addition to 10/2011
  • Bisphenol A is currently sat in a slightly odd position, as it's still permissible in the EU (with exceptions around e.g. bottles for babies) with a relatively recently reduce migration limit, but France has banned it. This is a bit problematic in terms of how EU law is supposed to work! Nonetheless it remains somewhat vilified in Europe, so if you can avoid packaging that uses it then it's likely to be the most popular approach with customers here ;)

 

 

Perfect, 
 
I will review and implement the changes that you comment on, and I will request more information from the suppliers to verify that I do not "forget" to place any other legal requirements. 
 
thank you :) 





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