5 replies to this topic

[Olenka01]

Hi,

 

EFSA is banding TiO2 to be used as additives.

Does anyone know if standard migration testing includes TiO2 please, or it something that will need to be added?

I have queries from one of the customer when it's going to be remove from packaging and ink. Of course, it wont be, but not sure if its cover under current testing, or should this be somehow included to our CoD to cover the subject.

[pHruit]

Welcome to the forum

EFSA's assessment specifically relates to the use of TiO2 as a food additive, so it's the authorisation for use as an additive under Regulation (EC) 1333/2008 that is being withdrawn. The change in regulation on food additives has no bearing on the composition of packaging materials.

 

I'm not sure there is such a thing as "standard" migration test, as the test scope and methodology is dependent on what is being tested and why - for example, the different "simulants" detailed in Regulation (EU) 10/2011. You'd probably need to ask the lab you use for your current migration testing whether this is in the scope they currently provide for you, and if not, whether they could add it. I've not had cause to look into how feasible that would be, but it can't hurt to ask.

 

You may of course find yourself in a difficult position with the customer where they decide they don't like TiO2 at all due to recent press coverage, even if your application uses it in a completely permissible manner. If you're part of any sort of industry body/association then I'd probably also raise it with them, as if you're being asked this then you're probably not alone, so a unified industry position might be helpful

[Schwalb]

Titamum oxide is listed in Regulation (EC) No. 10/2011 as an FCM (Food Contact Material No.: 610).

 

 

https://eur-lex.euro...4182830&from=DE

 

It is therefore necessary to have the supplier confirmation that this substance has not been used in the manufacture of the packaging.

[Foodworker]

EFSA at this time are only talking about a Titanium Dioxide ban in food.

 

It is, as said above, used within some packaging materials and would need to be stated on the Declaration of Compliance as a Dual Use substance. There are no current published plans to also ban it from packaging materials, and if it were, it would require another amendment of EU10/2011 for plastic applications. the plastics regs are where most specific bans or limitations are stated.

 

However it is listed as a Substance of Potential Concern and some more knowledgeable customers will ask if it can be removed from packaging. These are often French, Swiss or German customers and momentum will build for its removal over the next couple of years.

 

With respect to testing, by 'standard migration', I guess you mean overall migration. It will not show in this.

 

If you believe that it is used as a constituent, you should be requesting a specific analysis.

 

You don't say what field of packaging you are working with but if for example there is a white plastic component, there is a high probability of TiO2 being used and you should initially ask your supplier for a statement. Depending upon the response, you need to risk assess the probability of it exceeding the current Specific Migration Limits.

[DN_QAMGR]

Hi, from the US! 

 

Titanium Dioxide is used in colorants (white). 

 

I'll be paying attention to this thread and how EU expects you to prevent the use of this as a component if it is an additive for packaging color. 

 

Sorry I'm of no help, but glad everyone is proactive!

[JensV]

Hi all! Belgium here!

 

In our food processing company, we do use for the primary packaging of some products white plastic foil. This white foil is sealed on top of a cup and can come in direct contact with the actual food product.

 

We do have a Food Contact Compliance Statement Sheet from the supplier for the white foil. Regarding Titanium Dioxide, the following is mentioned:

 

----

The material can show trace of substances in compliance with Regulations 1333/08/CE e 1334/08/CE (named as “dual use” additives).

At present, our suppliers informed about presence of the following dual use additives:

...

CAS-No 0013463-67-7 / TITANIUM DIOXIDE (E 171).

...

 

According to experimental and theoretical calculations, these substances are compliant with the Regulation 10/2011/UE, Art. 11 comma 3, letters a,b of DM 21 March 1973.

 

It is the end user’s responsibility to inform XXX (= name of the supplier) about possible restrictions due to aromas or additives presence in the packed food product.

---

 

The Food Contact Compliance Statement Sheet dates from February 2020. If aunderstand correctly, Titanium Dioxide isn't a "Dual Additive" anymore? So I think it is best we should ask the Supplier for a review of this statement?

 

Thank you,

Kind regards

Edited by JensV, 08 July 2022 - 07:23 AM.