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Food for Thought
October 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.

NGOs call for hazardous chemicals to be addressed in packaging laws

Civil society organisations, including Zero Waste Europe, have published a joint statement calling for the Packaging and Packaging Waste Regulation (PPWR) to address hazardous chemicals.

The statement highlights studies that show widespread exposure of European citizens to harmful chemicals, including substances that have been found in food packaging and other food contact materials. It states that progress towards more reusable and recyclable food packaging must go hand in hand with chemical safety, and urges the EU to introduce rules within the PPWR to eliminate unsafe chemicals from packaging.

Read the joint statement here.

Recycled plastic content in Food Contact Materials

When it comes to food contact materials, the use of recycled content that has been contaminated by hazardous chemicals creates new pathways through which people can be exposed to these substances.

In September 2022, the European Commission adopted the Regulation on recycled plastic materials and articles intended to come into contact with foods, to attempt to address these pathways and provide a harmonised legal framework across the EU. DG Sante provided the most recent updates on the implementation of the regulation in July (p. 28-34).

The Regulation requires that from July 2023 onwards, only plastics containing recycled plastic manufactured with a 'suitable' or 'novel' recycling technology may be placed on the EU market. The plastics must also be manufactured by registered facilities. Voting on the first authorisation decisions for these technologies and facilities is predicted to take place in Autumn 2023.

However, some civil society organisations remain concerned that the regulation may not be able to ensure consumer safety, as current recycling technologies have not yet proved to be able to remove all toxic chemicals present in the plastic. For more information, see Zero Waste Europe's 2022 policy briefing 'Ensuring safe recycled content in food packaging: ambition vs reality'. The briefing analyses civil society's immediate concerns and provides a number of recommendations for policymakers, authorities and packaging manufacturers.

European Parliament votes to better protect health and the environment with the reform of the CLP legislation 

Members of the European Parliament have adopted their position on the revision of the legislation on the classification, labelling and packaging of chemical substances and mixtures (CLP). The vote represents a crucial step in the reform process of the CLP regulation, which sets out how the EU classifies and communicates about hazardous chemicals used in a wide array of consumer products.

The EU rules on the classification, labelling and packaging of chemicals are a key cornerstone of Europe's chemicals legislation. Civil society groups and coalitions like the Health and Environment Alliance (HEAL) and EDC-Free Europe welcomed the outcome of the vote, which saw an overwhelming majority of MEPs (519 votes in favour, 99 against and 8 abstentions) support a strong Parliament position on the CLP reform.

Following the adoption of the European Parliament's position on the CLP reform, the trilogue negotiations with the European Commission and the Council can begin under the lead of the Spanish EU presidency this autumn.

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. ZWE advocates 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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