- Practical Guide -
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10.4. Recycling for food application
Recently, an increased interest has been noted in Europe for recycled and/or reused materials
in the sector of materials and articles in contact with foodstuffs. The matter will be
considered during 2003.
New procedures for recovering monomers from recollected used articles have been
introduced, e.g. involving depolymerization. The Commission considers that these monomers
can be used as starting substances for the manufacture of plastics intended to come into
contact with foodstuffs, provided they comply with the applicable EEC Directives. As
regards the purity criteria of the mentioned monomers, see Directive 2002/72/EC
Irradiation, microwave and other physical treatment
These specific issues are not yet considered by the Directive 82/711/EEC [A6] laying down
the basic rules for testing migration properties.
Enforcement of legislation and methods of analysis
11.1. Enforcement of legislation on food contact materials belongs to the more general issue of
enforcement of legislation on foodstuffs, and all the rules applicable to the latter are, mutatis
mutandis, applicable to the former.
11.2. The main rules are those provided by the Directives 89/397/EEC, 93/99/EEC and
85/591/EEC. The references can be found in the document "EU and national legislation".
Other rules and guidelines can be found as regards the checking of the migration in the texts:
Directive 2002/72/EC, Annex 1;
Directive 82/711/EEC and its amendments;
"Commission Explanatory Guidance on Migration Testing", Chapter IV in "Note for
11.3. In the absence of binding rules at the EU level, the Member States are responsible for the
enforcement of the EC Directives.
11.4. In the Annexes, guidelines are given on two problems intensely debated at EU level:
The use of mathematical models to replace migration testing (see Annex 1);
The methods recommended for the verification of the quantitative restrictions
established in the Directives, such as SML, QM, QMA, OM (see Chapter III).
11.5. A short summary of an EC research is reported in Annex 2 to assist the industry and official
laboratories in enforcing the legislation.
See Annex 2, paragraph 4.