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intended to come into contact with food and additional national regulations for food contact materials. According to GMP rules, it is the responsibility of the party placing the final package onto the market to confirm that the package is compliant.
FINAT therefore recommends its members to be fully aware of GMP procedures and always ensure they comply with appropriate processing conditions applicable to supply to the food industry. In line with this recommendation, it is advisable to use self-adhesive labelstocks which are thoroughly tested and certified for direct and indirect food applications by independent testing institutes like ISEGA.
In 2010, turbulence in the label market was created by misleading headlines in UK media about possible migration of a chemical used in adhesives through packaging into food. Reference was made to findings of a research paper written by the Spanish University of Zaragoza (UNIZAR) for the Royal Society of Chemistry’s Journal of Materials Chemistry. FINAT approached all stakeholders concerned to exchange information and clarify the matter.
As it appeared, UNIZAR was one of the research partners in MIGRESIVES, an EU funded project initiated by the European adhesives industry itself involving a total budget of 3 million and 21 partners across 8 countries. Aim of the project was to develop a pragmatic, science based tool to support existing and future EU regulation for adhesives used in food packaging. The UNIZAR research that reached the UK media was only a small part of this project. The laboratory samples were made for scientific experiment only and were not representative of the concentration levels used in commercial adhesive formulations or food packaging.
An information paper was posted on the members’ section of the FINAT website along with explanatory notes from FEICA (the European adhesives association) and ISEGA (the re- nowned food compliance testing institute from Germany). Regarding Food Contact and Sustainability, FINAT is a member of CITPA, the European umbrella organisation for the paper and board converting packaging industry, which together with CEPI (the paper and board manufacturers’ federation) has issued an Industry Guideline for the Compliance of Paper & Board Materials and Articles for Food Contact. FINAT is participating in the Product Safety Working Group of CITPA, the association’s expert forum on issues relating to food safety.
reach revision and clp
In 2012, a review of REACH is scheduled, with supporting studies already underway. This provides a natural opportunity to make sure the self-adhesive labelling industry’s interests are
taken into account.
The EU Regulation on Classification, Labelling and Packaging (CLP) places new legal obligations on companies operating in the EU market. Under the CLP Regulation, hazard information will be made available on the labels of substances and mixtures. Pictograms, signal words, hazard statements and precautionary statements will allow manufacturers, importers, downstream users and distributors to easily share infor- mation on the hazards of substances and mixtures.
With respect to REACH, FINAT is involved in a lobbying platform called ‘CheMi’, the consortium of associations representing the ‘downstream users’ of chemicals. This platform has recently been given seats in two key transectoral committees overseeing the implementation and revision of REACH. The appointments are crucial in securing that the needs of downstream manufacturing industries are sufficiently taken into account in monitoring the implementation and the revision of the regulation.
ippc and ied
The Integrated Pollution Prevention and Control directive (IPPC) involves Best Available Technique Reference Documents (BREF’s) which are important guidance documents for competent authorities with respect to the issuing of permits. For the self-adhesive labelling industry, the BREF on surface treatments using solvents is important. One of the major concerns with respect to this Solvents BREF is the definition of the threshold that determines whether or not a company is included in the directive or not. The Industrial Emissions Directive (IED) combines the IPPC together with six other air pollution directives and entered into force at the beginning of 2011. Members States have until 7 January 2013 to transpose the IED into national law.
in conclusion
Public affairs is a continuous process and FINAT has recogn- ised the need for pro-active engagement by embracing the subject of sustainability as a direct Board matter, with the multidisciplinary support of the Technical and Marketing Committee. Members are advised to check the new FINAT Member Community website for regular updates on the dossiers above and more.
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FinAt YeARbooK 2011 |