Materials in contact with food
ANEC published a position paper entitled "ANEC reflections on the basic directions for the future development of the EU legislative framework on Food Contact Material (FCM)" in December 2020. This paper was drafted by F. Fiala, Head of Office of the Consumer Council. It addresses the fundamental deficits of the European regulatory framework in this area and highlights the inactivity of the EU Commission and its stranded activities.
Further, it critically reviews assessments and key concepts by Konrad Grob (former Swiss civil servant) who made many publications in this field. Apparently he impressed the EU Commission with his thoughts. Whilst ANEC welcomes his key points of criticism showing that the current system is dysfunctional his suggestions of the way forward promoting more industry self-control and involving private certification bodies approving materials and associated limits (instead of the regulator) cannot be supported.
By contrast, ANEC supports a strengthening of public authorities, a radical reduction of substances and materials, rigorous bans of the most hazardous chemicals (e.g. CMRs) in all materials, a pre-market approval system for substances and materials (including "non-intentionally added substances") for each use, an expiry date for all authorisations and a fee system for authorisations and market surveillance. The position paper can be downloaded here.