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Food for Thought
April 2023
Welcome to 'Food for Thought', a newsletter sharing key updates on food contact material (FCM) policy, ideas for revised FCM legislation and useful resources. There are thousands of chemicals in food contact materials that can potentially migrate into our food or drink, and many of these chemicals can harm our health and pollute the environment. This is why we need more protective regulation.

Packaging and Packaging Waste Regulation public consultation - deadline for comments 24th April

The European Commission’s proposal for a new EU Packaging and Packaging Waste Regulation (PPWR, which is the revised Packaging and Packaging Waste Directive) is out for public consultation, with a deadline of 24th April 2023.

The proposal currently sets three core objectives: 1) to reduce the current production of packaging waste; 2) to promote cost-effective circular economy principles across the industry; and 3) to increase the use of recycled materials in packaging. The proposal prioritises prevention and reuse, however it offers too many loopholes and exemptions to effectively reverse the growing levels of packaging waste, and it fails to incentivise the elimination of harmful chemicals in packaging.

Several NGOs (Rethink Plastic Alliance, ANEC, Zero Waste Europe) are therefore calling for  consumer safety to be considered in the PPWR proposal. This should be done holistically, and consider: the role of chemicals and their impacts on the environment; consumer health and circularity, in line with the Commission’s  Chemicals Strategy for Sustainability, which calls for non-toxic material cycles; and the reduction of substances of concern in consumer products, including packaging and food packaging. 


There is still time to provide feedback on the PPWR proposal through the public consultation process - the deadline is 24th April 2023, midnight Brussels time.

New survey on consumer attitudes towards food packaging

Last week BEUC – the European Consumer Organisation – published the results of a survey investigating consumers’ attitudes towards food packaging, and exploring their experiences, behaviours, and awareness of food packaging -related health risks. BEUC members surveyed consumers across Austria, Belgium, Czechia, Denmark, Germany, Italy, Norway, the Netherlands, Portugal, Slovenia, and Spain during October 2022.

The survey found that most consumers (70% of those surveyed) are worried about the impact of chemicals in food packaging and kitchenware on their health. And 9 out of 10 support stricter rules to prevent health impacts from chemicals in food packaging.

The survey also highlighted that some consumers continue to use food containers and kitchenware after they are worn or damaged, which can increase the risks of chemicals leaching into food. 

BEUC calls for the EU to adopt a preventative approach to chemicals present in food packaging and kitchenware, in line with the EU’s Chemicals Strategy for Sustainability and consumer expectation, including a default ban on all chemicals of high concern.

Read the full report here.

EU court concludes BPA is a substance of very high concern for wildlife

A recent ruling by the EU Court of Justice concludes that bisphenol A (BPA) has correctly been categorised as a substance of very high concern for wildlife by the European Chemicals Agency (ECHA). Bisphenols – including BPA – are commonly used in the production of plastics, including for food packaging. 

In 2018 ECHA ruled that BPA should be classified as a substance of very high concern, due to its hormone disrupting properties on wildlife. PlasticsEurope – a trade association representing the plastic industry – has spent five years arguing and appealing against this classification. The EU Court of Justice ruled against PlasticsEurope’s latest appeal, agreeing that ECHA had correctly classified BPA as a substance of very high concern for its hormone disrupting potential on wildlife. 

Classification as a substance of very high concern means companies who choose to continue using BPA must communicate information about it to customers, clients and public authorities. It also signals to market investors that it is time to seek safer alternatives.

Read more in CHEM Trust’s news story.

This newsletter is produced by a collaboration between CHEM Trust, the Health and Environment Alliance (HEAL) and Zero Waste Europe (ZWE). Together, we are working towards creating a toxic-free environment where nobody should have to worry about the presence of health-harming chemicals in the products that come into contact with our food.

CHEM Trust is a charity based in Germany and the UK, with the overarching aim to prevent synthetic chemicals from causing long term damage to wildlife or humans, by ensuring that chemicals which cause such harm are substituted with safer alternatives. (EU Transparency number: 27053044762-72)

The Health and Environment Alliance (HEAL) is the leading not-for-profit organisation addressing how the environment affects human health in the European Union (EU) and beyond. HEAL works to shape laws and policies that promote planetary and human health and protect those most affected by pollution, and raise awareness on the benefits of environmental action for health. (EU Transparency number: 00723343929-96)

Zero Waste Europe (ZWE) is the European network of communities, local leaders, experts, and change agents working towards the elimination of waste in our society. We advocate for sustainable systems and the redesign of our relationship with resources, to accelerate a just transition towards zero waste for the benefit of people and the planet. (EU Transparency number: 47806848200-34)
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