I have been asked about the Migration, and Heavy Metals by our customer. We convert board to food contact packaging . Our supplier has supplied a compliance with 1935/2004 & 2023/2006 declaration. I can see that this covers hazardous migration components and GMP but not specifically Heavy Metals. IS the 1935/2004 an umbrella reg that covers every thing?
Is there a guide to how these regulations relate to each other please. Like a family tree? As we are cardboard we do not need to comply with the 10/2011 for plastic so compliance with the 1935/2004 (general migration) is enough.
The other query I have is that The Heavy Metal Directive 94/62/EC is concerned with waste disposal as well as migration. If the material has low heavy metals & complies with food contact migration, is it a given that it is low enough to comply with the waste limits?