REACH and food contact materials ...

REACH (Registration, Evaluation and Authorisation of CHemicals) came into force on 1st June 2007 (EC Regulation No. 1907/2006) with the aim of establishing a single system of registration, evaluation and authorization of chemicals by 2018. Any substance produced or imported into European Union  with more than one tonne per year must be registered with the new European agency located in Helsinki (ECHA: European CHemicals Agency). In addition, an authorization procedure is obligatory for all substances considered "very high concern" (SVHC: "Substances of Very High Concern"), without limit of tonnage, with the aim to promote substitution of these substances.

How can companies that manufacture, import or use of materials in contact with food are they impacted by REACH?

For substances used in the manufacture of food contact materials, they are subject to registration procedures of REACH if the materials involved are manufactured in the EU. However, when a report on chemical safety is established, it is not necessary to cover risks on human health that are already covered by EC Regulation No. 1935/2004. By cons, this report must take into account the risks to the environment and risks to human health in cases of other uses of the substances. With respect to substances SVHC, listed in Annex XIV of REACH, which have been authorized for use in food contact materials, they are exempt from the permit procedure. However, in the context of using these substances for manufacturing materials, an authorization may be necessary insofar as the regulation of food contact materials is designed to protect people as consumers but not as workers. Finally, all these substances are subject to the restrictions set out in Annex XVII of REACH.

In regard to food contact materials constituting the packaging, consumer products or pieces of equipment of food industry, they are considered, under REACH, as articles for which manufacturers and importers are subject to the following obligations, except exceptions :

- Registration of substances present into articles when these substances are intentionally released from the constituent material, under normal use and reasonably foreseeable and in quantities above one tonne per year;

 - Notification to the ECHA of any substance contained in the candidate list of SVHC when the concentration is above 0.1% weight/weight and the substance is present in all articles produced or imported over one ton per year, and this from 1 June 2011.

Finally, a supplier of items intended to be in contact with foods containing substances on the candidate list of SVHC with more than 0.1% weight/weight, must communicate downstream sufficient informations to enable safe use. This requirement is applicable from  28 October 2008.

To help companies meet the requirements introduced by REACH,  LNE offers a comprehensive support program: initial diagnosis, inventories of substances entering and leaving the company, post-inventory diagnosis, Assistance for providing informations, intra or inter training, performance of analytical tests on materials, ... For more information, send an e-mail to the following address: info@lne.fr

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