Industrial guidelines for traceability of materials and articles for food contact

4.3.1 Objectives and contributors to the guidelines

As already highlighted in the previous section, the associations representing the food contact materials and articles industries have been requested by the Commission to develop guidelines that would help the industry to harmonise the procedures adopted to achieve the objective set forth by Article 17 of Regulation 1935/2004/EC. These Guidelines have been prepared by a team representing virtually all the food contact materials industries; the team was led by EuPC, the European Association of Plastics Converters (see Fig. 4.1). The Guidelines are published in the form of a Code of Practice. This Code

• APEAL, Association of European Producers of Steel for Packaging

• BLIC, European Association of the Rubber Industry

• CEFIC FCA, European Council of Chemistry, Food Contact Additives

• CEI-Bois, European Confederation of Woodworking Industries

• CEPE, European Council of Paint, Printing Inks and Artists' Colors Industry

• CEPI, Confederation of European Paper Industries

• CIAA, Confederation of the food and drink industries of the EU

• CIPCE, Comité International de la Pellicule Cellulosique

• CPIV, Standing Committee of the European Glass Industries

• EAA, European Aluminium Association

• ETS, European Tissue Symposium

• EuPC, European Plastics Converters Association

• EuroCommerce, the retail, wholesale and international trade representation to the EU

• FEFCO/ProBox, European Federation of Corrugated Board Manufacturers

• FEVE, European Container Glass Federation

• FPE, Flexible Packaging Europe

• PLASTIC EUROPE, Association of Plastics manufacturers in Europe

• SEFEL, European Secretariat of Manufacturers of Light Metal Packaging

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

is available in the Community Joint Research Center website10 and it was submitted to the European Commission for comments in January 2006. Converters and raw materials producers were the main contributors to the Guidelines although representatives of the food industry and retailing industry provided their view, especially in the preparatory phase. It was recognised, however, that their needs in terms of traceability for food contact materials and articles are rather different from those of converters and raw materials producers, and are solely related to the need for creating and maintaining a link between the identification of food contact materials and the identification of food and food components to fulfil Article 18 of Regulation 178/2002/EC.

4.3.2 Structure of the document

Some elements in the Guidelines are common to all materials and articles, while internal codes of practice are different in relation to the chemical and manufacturing processes. For this reason the Guidelines have been divided into two sections, the former dealing with all common elements and the latter composed of several subsections, each of them dealing with one specific material. The structure of the Guidelines is reported in Fig. 4.2.

4.3.3 Involved stakeholders

The different stakeholders involved along the supply chain of food-contact materials and articles are reported in Fig. 4.3. Taking as the central point where the food contact material or article is manufactured, i.e., the converters



II. 1 Materials II. 2 Applications





VI. 1 The role of quality systems VI. 2 The industrial practice VI. 3 Need for quality systems

VI. 4 Requirements for shipped materials and articles VII LEVEL 2: TRACEABILITY ALONG THE SUPPLY CHAIN

VII. 1 Materials and articles already in contact with food

VII. 2 Food contact materials and articles not yet in contact with food VII. 3 Food contact material and articles that can reasonably be expected to be brought in contact with food or to transfer their constituents to food under foreseeable conditions of use



ANNEX I. Associations which participated in the document ANNEX II. The Guidelines

Part 1 Traceability applied to glass packaging containers (bottles and jars)

Part 2 Traceability applied to metal packaging for food and drinks

Part 3 Traceability applied to the paper chain

Part 4 Traceability applied in the plastic chain

Part 5 Traceability applied in the regenerated cellulose film sector

Part 6 Traceability applied for food contact materials in the rubber industry

Part 7 Traceability applied for the tissue sector

Part 8 Traceability applied in the wooden crate industry

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

or producers, we can identify an 'upstream' and a 'downstream', as indicated. Converters transform materials that have been produced by upstream suppliers into finished articles or semi-finished goods, consisting essentially of the same materials. Producers manufacture articles directly from starting materials, using processes involving chemical, as well as physical change. To achieve the objective of tracing a food contact material or article it is necessary that the relevant information be passed along the chain from one stakeholder to the next and that such information is managed so as to maintain the link between incoming goods and outgoing products of the concerned stakeholder.

The scheme reported in Fig. 4.3 assumes that the whole chain is within the European Union, where Regulation 1935/2004/EC is fully applicable. However, in some cases, part of the chain can be outside the EU, therefore another business must be put in the scheme, namely the importer. Import may take place at different levels, such as importing

• starting materials by the converters and producers

• empty packaging by distributors or fillers

• food contact articles by distributors or retailers

• filled food contact materials and articles by distributors or retailers.

It is evident that importers of food contact materials in the EU can only guarantee that suppliers and goods imported are appropriately identified and are accompanied by a declaration of compliance ensuring that the imported products fulfil the EU legislation in the relevant area of food contact materials and articles. But importers are not in a position to ensure that the same rules of internal traceability are followed by manufacturers located outside the Community. These manufacturers have a legal obligation to comply with the food contact regulation in force in the EU when selling here but they are not subjected to the same internal traceability. This creates discrimination between converters and producers located within or outside the EU, the former being forced to sustain extra costs that are unlikely to result in additional benefit to consumers.

Producers + converters (process to the finished product

Starting substances



Producers + converters (process to the finished product

Distributors/agencies Fillers/packers


Distributors/agencies Fillers/packers



Final consumers

Fig. 4.3 Parties involved in traceability of food contact materials and articles.

72 Chemical migration and food contact materials 4.3.4 Use of the guidelines and future trends

The Industrial Guidelines paper on traceability of food contact materials is not conceived as a procedure but rather as guidance to develop specific procedures that can be adapted to the needs of each single industry. It is expected that all elements addressed in it would be reflected in the company's quality system. For this reason they do not explicitly suggest the use of any specific quality or system of Good Manufacturing Practice. Some companies may not have the critical mass for being accredited through a certified quality system. Nevertheless, they should always establish an equivalent traceability system internally. ISO 9000 is not the only system requiring industry to establish procedures for traceability. Other systems, such as those in place in many industries, have the same requirement.

Whatever procedure is adopted, it is essential that every manufacturer of a food contact material or article maintains a documented system aimed at identifying and preventing the production of defective products and, in the case of delayed defects detection, allowing appropriate product recall. The Guidelines are also conceived as an open document, to which other sector associations can contribute with a description of their own practices (in Annex II), thereby increasing their relevance and creating a shared background to attain the objective.

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