The Committee, taking into account also the analysis of the situation by the
Commission task force, offers the following views on the questions as posed by the
Commission in the terms of reference.
Can a consumption of 200 g fat/person/day be considered a realistic maximum
Yes. The Committee agrees that the consumption of 200 g fat/person/day can be
considered a realistic maximum intake.
Could the Committee accept an adjustment to the present convention by introducing a
"fat (consumption) reduction factor" (FRF) in the estimation of the exposure to a
migrant in fatty food?
Firstly the Committee notes that the introduction of a FRF in the estimation of
exposure, would not influence the opinions expressed by the Committee for the
substances classified in SCF lists 0, 1, 2 and 4
. Only substances classified in list 3
may be affected if the FRF were introduced. The existing restrictions
term of concentration in food have been used by the Committee taking into account
the current system and its conservative assumptions. For these SCF_List 3
substances the correction due to the introduction in the system of the FRF would be
limited because the proposal is to limit the scope of FRF to only lipophilic substances
and only to foodstuffs containing more than 20% of fat (see 1.3.1)
Moreover the Committee recognises that the current EU system of the evaluation of
the exposure to a migrant from food contact materials is conservative and other upper-
bound assumptions are made. For example, the assumption that all the 1 kg food
eaten each day is in contact with a plastic that releases the substance at the highest
concentration (the SML) permitted. On the other hand, the present system does not
take into account possible exposure from other, non-packaging, sources. In total, the
introduction of FRF for lipophilic substances and for fatty foods only, would still
leave the whole system conservative.
In conclusion the Committee can accept the conclusions reached by the Commission
task force (2) and has no objection to the introduction of a "fat (consumption)
reduction factor" in the way proposed (1) for estimating exposure to a substance
migrating into a fatty food.
SCF_ list 0 is related to substances which have not any restriction. SCF lists 1 and 2 are related to the
substances for which the SCF has established respectively an ADI or TDI. SCF list 4 (substances which should
not be detectable in foodstuffs) is not affected by FRF because the FRF does not apply to these substances.
SCF_List 3 list 0 is related to substances for which an ADI or a TDI could not be established, but where the
present use could be accepted.