Hello
An operator wishing to market materials and articles intended to come into contact with food in the EU must comply with the specific European regulation, Regulation EC 1935/2004, which establishes labeling requirements and requires the material or article to be accompanied by a written Declaration of Conformity.
If the material or article is made of plastic, it must also comply with the specific regulation for this type of material (Regulation EU 10/2011), which includes an annex with the model Declaration of Conformity to be used. This Regulation establishes a specific migration limit for ESBO that is quite high (60 ppm), indicating that this component is not allergenic. Indications that a food contains or may contain allergens are regulated in the EU by the regulation governing food labeling, and must be clearly marked on the list of ingredients.
The components of a food's packaging are not ingredients of that food.
If a component of the packaging appears in the food, it is only the result of migration.
If a package complies with EC Regulation 1935/2004, it must comply with the Specific Migration Limits established by that Regulation. It is doubtful that an object or material intended to come into contact with food that complies with the applicable regulations, including the migration limits for ESBO, could endanger the health of a consumer allergic to soy.
If ESBO present in a package migrates to the food contained within that package up to the established limit of 60 ppm and is capable of producing an allergic reaction in a consumer, we are facing a real problem and the specific migration limit for ESBO should be immediately reviewed.
Regards