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Food packaging made from recycled paper and board: an overview of European legislation

Environmental considerations have created a growing trend toward increased utilization of recycled paper fibers in packaging production. Recycled fibers are also often used in the production of food packaging applications. Being the part of the food production chain, the safety of food packages is as important as the safety of food itself. However, due to the fact that a significant portion of recycled fibres has been printed at some point, the suitability of using recycled fibre from printed sources in food contact applications is still being largely debated among the scientific community, since it is difficult to exclude exposure to traces of ink chemicals, varnishes, and adhezives in recycled fibres. Considering that the origin and composition of the recycled fibers are usually difficult to detect, recycled paper and borad must be used with special caution in the production of food contact materials. There is currently no harmonized EU legislation on paper and board articles and materials for food contact applications, as well as on the use of recycled paper fibres in contact with foods. In addition, there is also a lack of the specific directive about paper and board coming into contact with foods. The main rule for paper and board food contact applications comes from the EU Framework Regulation (EC) No 1935/2004 and the Regulation on Good Manufacturing Practice (EC) No 2023/2006. Framework Regulation covers all materials that come into direct contact with food and it sets some general requirements with which all food contact materials must comply with. It states that substances that might endanger human health must not be transferred from packaging into the packed food in quantities which could endanger human health or bring about an unacceptable change in the composition of the food or deterioration in its organoleptic characteristics (essentially its taste and smell). The Framework Regulation only provides the principle, whereas the exact methodolgy of how to prove safety is missing. In the absence of the specific directive, some European countries have developed their own national provisions specific to paper and board (e.g. Germany, France, Italy, and the Netherlands). In addition, the Council of Europe (COE) has published nonlegal binding Resolution AP (2002)1 on paper and board materials and articles intended to come into contact with foodstuffs, which can act as a reference for countries that have not yet established national regulations of their own. However, the existing national laws, regulations and recommendations are not always well aligned and that may cause some confusion and uncertainty, as well as prevent fair competition and free trade of paper and board within the EU. Likewise, a lack of the specific directive for paper and board food contact materials has created disadvantage in the market because paper and board materials appear to be “unregulated”. In response to this situation, the European paper and board food packaging supply chain comprising CEPI, CITPA, CEFIC and FPE has developed an Industry guideline for the compliance of paper and board materials and articles for food contact. The aim of this document is to provide a single text that can be used by all operators in the paper and board packaging supply chain in order to establish compliance with Framework Regulation 1935/2004.

food packaging; recycled paper and board; food contact; EU legislation

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