In an article published on June 19, 2022, in the Journal of Consumer Protection and Food Safety, Malte Glüde from the Chemical and Veterinary Analysis Agency (CVUA), Fellbach, Germany, and co-authors reported on a workshop for European Union agencies on the enforcement of compliance work for food contact materials (FCMs) on the European market. 84 people participated online in September 2021 and the majority who provided feedback “found the workshop helpful and inspiring.”
Glüde and co-authors described that the rationale for organizing the workshop was that the enforcement of the FCM regulations in Europe is weak. One major reason for this is the high number of chemicals that may be used in FCMs. Under Regulation 2023/2006 on Good Manufacturing Practice (EC 2023/2006) every business operator that contributes to the manufacture of an FCM needs to perform compliance work to guarantee the safety of its product. This also means that enforcement agencies need to know and inspect all business operators to check if they complied with Regulation (EC) No 2023/2006 and if a product is safe.
During the workshop, the participants compiled “a toolbox for enforcement authorities.” It includes a letter specifies the product controlled and the aspects the compliance works is auditing. Enforcement agencies can send it to business operators who again are asked to forward it to their suppliers. This way the chain of business operators around the world can be tracked. The toolbox also summarizes the way authorities can check documents for compliance and potential measures in case of non-compliance. Further sessions of the workshop gave insides on past experiences with enforcing Regulation (EC) No 2023/2006 in Germany and Switzerland and the concept of how business operators in Demark inspect food contact business operators. Ideas for enforcement campaigns were also collected.
The authors concluded that the workshop helped to make more enforcement agencies aware “of the most efficient way to control compliance with article 3 of Regulations 1935/2004.” In the future, Glüde and co-authors stated, “the most challenging part for enforcement authorities is finding suitable measures in case of non-compliance in the supply chain outside the area of jurisdiction or even outside the EU. As a worst case, a ban on imports must be considered.”
In 2020 German consumer organizations included inadequate enforcement by authorities as one hole in current EU FCM regulations hindering consumer protection from hazardous chemicals (FPF reported). In June 2022 the European Commission published a working document on the evaluation of the EU FCM legislation in which it expressed a clear need to reinforce the system of enforcement (FPF reported).
Reference
Glüde, M. et al. (2022). “Virtual workshop on the enforcement of compliance work for food contact materials in Europe.” Journal of Consumer Protection and Food Safety. DOI: 10.1007/s00003-022-01382-0
