Traceability and food contact materials

Dainelli, Sealed Air Corporation, Italy and The European Plastics Converters Association (EuPC), Belgium 

Framework Regulation 1935/2004/EC covers all materials and articles that (a) are intended to be brought into contact with food or (b) are already in contact with food and were intended for that purpose or (c) can reasonably be expected to be brought into contact with food or to transfer their constituents to food under normal or foreseeable conditions of use (Article 1.2). In Aimex I of the Regulation are listed the materials and articles that shall be covered by specific measures, i.e., 

The field of application, however, is not limited to the above-mentioned materials and articles but would include other products provided that they fulfil the requirements of Article 1.2. In the field of plastic materials, for example, not only plastics for wrapping foodstuffs are covered, but also plastic laminates used as inner parts of furniture or fridges with which food may be put in contact. 

This also implies that, in the opposite direction, the material or article can be traced from any point in the chain down to the retailing point. In other words, if traceability can be described as the possibility to trace back from finished goods shipments to raw material lots, this should not neglect that there is a need to trace forward from raw material lots to identify all finished goods shipped. In fact traceability was introduced primarily for ensuring that defective food contact materials are identified and withdrawn from the market, in particular as far as compliance with the applicable legislation is concerned. If a given raw material is found in violation of the law, or such as to impair safety of the finished product, traceability systems shall be such as to allow withdrawal of all other finished product in which the concerned raw material has been used. To achieve this objective both levels must function properly. 

Traceability is addressed in Article 17 of this Regulation, which reads as follows  

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Fig. 4.2 Structure of the Industrial Guidelines for Traceability of Food Contact Materials and Articles.

Fig. 43 Parties involved in traceability of food contact materials and articles.

Paragraph 1 explains the rationale under which traceability is established. It should be noted here that all the stakeholders are expected to benefit from the introduction of the Article public authorities, because of facilitation of control, manufacturers and users of food contact products, who will benefit from recall and easier attribution of responsibility, and finally a stricter regulation of traceability would give additional reassurance to consumers. As stated above, the main reason for traceability procedures having been introduced by food contact materials producers was related to defective product recall, i.e., linked to potential technical failure of them, rather than health hazards (that are extremely unlikely). Therefore such a paragraph can be interpreted as a measure of prevention that is not deemed to bring extra safety factors to the final consumers. 

In relation to the previous two sections, this is not a separate category of food contact materials and articles when it comes to traceability information and its flow in the supply chain. The peculiarity here is the point at which the material or article is identified as coming into contact with food, and the fact that this contact can be indirect. Therefore the starting point of the traceability chain can be quite different from that of more traditional food contact materials and articles, but the end point still is the retailer, at which point the material is either in contact with food or not. Thus the previous two paragraphs apply, depending on the circumstances. 

Traceability systems already exist in the food contact material distribution chain, mainly to address quality problems that may arise with use. ISO-certified companies, as well as companies operating using Good Manufacturing Practice, not only adopt these systems internally, but also require their suppliers, service companies and manufacturers to use them, so that traceability is a common and widespread feature of food contact materials in the European... 

Industrial guidelines for traceability of materials and articles for food contact... 

Fig. 4.1 Contributors to Industrial Guidelines on Traceability of Materials and Articles for Food Contact (also referred as the Code ).

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