Chemical migration, food packaging and the Code

FSANZ is in the process of reviewing the Food Standards Code in relation to chemical migration from packaging into food, but what does this mean for food manufacturers?

It is an offence to sell food packaging or handling materials that are unsafe or will make food unsafe, but the Code does not yet comprehensively pin down at what level or exposure certain chemicals will become unsafe when used in packaging.

The Code – as it stands

Food businesses must comply with requirements in the Australia New Zealand Food Standards Code. Currently, there are four main areas of the code which cover chemical migration currently in force.

Standard 1.4.3 – Articles and Materials in Contact with Food

This standard specifies that any material in contact with food, including packaging material, must not cause bodily harm, distress or discomfort. But it does not specify materials that can be used in the manufacture of food packaging materials or the method of manufacture.

Standard 1.4.1 – Contaminants and Natural Toxicants

The standard includes maximum levels (MLs) for a few chemicals associated with migration from packaging, but is in no way exhaustive. It covers the real nasties, including vinyl chloride, tin, acrylonitrile (a genotoxic carcinogen) and other potential contaminants such as polychlorinated biphenyls.

Standard 3.2.2 – Food Safety Practices and General Requirements.

This Australia-only standard details requirements on food businesses to only use packaging material that is fit for its intended use; only use material that is not likely to cause food contamination; and ensure that there is no likelihood that the food may become contaminated during the packaging process.

The code needs work, and they’re getting there. But in the meantime, what should manufacturers do?

Dr Barbara Butow, a senior scientist at Food Standards Australia New Zealand, says manufacturers can look to EU and US regulations, which are more comprehensive than Australia’s current standards.

EU or US codes – how are the two different?

The EU requirements regulate migration limits and migration into food, whereas the US requirements are around the packaging itself.

“The USFDA requirements are incredibly detailed around what you can use your packaging for and under what conditions, so temperatures and times and for what materials,” Butow says.

“So the outcome is the same, as I understand it, but the way that you get there is slightly different. I think the EU regulations appeal to a lot of companies because it’s a level that can be measured, whereas the US regulations, they’ve got a database of Cumulative Exposure Data Intake (CEDI), which is around the exposure to the chemical from the packaging.”

Butow says manufacturers can help ensure their product is safe by going back to their suppliers for assurance.

I think they need to be aware what the packaging material is, what potential chemicals could migrate from there and under what conditions. If it’s a material that’s going to be stored for a long time, is it greater potential for migration or leakage of chemicals.

“They need to look at how’s it going to be stored and what food is the packaging going to be used for. All those things are good manufacturing practice. If it’s following GMP, then you can look at some of the iso standards. If people are concerned about mineral oils leaking from cardboards then maybe put a barrier in, although some people say the barrier might not be adequate.

“So there are codes of practice out there which describe all these things and then there’s a code of practice for printing inks, the EuPIA code of practice.”

Butow says that while food manufacturers can access international regulations, they’re not easy to navigate.

“[International regulations] are not a one stop shop and certainly the code of federal regulation in the US, you have to go through layers upon layers to get down to the chemical that you’re interested in to get the actual requirement. It is there, but not the risk assessment behind it.”

Is it safe?

Butow says that while consumers might not assume there’s regulation on absolutely everything, they “just expect packaging to be safe.”

“It’s only when there’s something on the news and again it tends to have a bit of an imported food bend to it than people’s ears prick up.”

“We really welcome input from industry, it’s just a call for information, a call for participation,” Butow says.

“So if and when we go down the track of adding a bit of regulation, or touching up the standard, at least we’ll know who to approach for input.”

Dr Barbara Butow presented at the 2015 National Technical Forums.


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