Letter from EnglandThe UK seeks to manage health risks in illegal imports of food packagingAbsence of global food packaging legislation arouses concern especially in the UK’s food service sector that products imported from outside the European Union can potentially fail to meet national and European food-contact standards so as to pose a risk to businesses and consumers. A competition issue that is undermining user confidence in levels of safety and hygiene, and moves to improve compliance overall and catch offending imports before they reach the UK market, were topics recently highlighted at a UK plastics packaging industry forum conducted by the British Plastics Federation (BPF).Absence of global food packaging legislation arouses concern especially in the UK’s food service sector that products imported from outside the European Union can potentially fail to meet national and European food-contact standards so as to pose a risk to businesses and consumersWhen eating on the go, consumers will often eat directly from the packaging, and for safety and hygiene reasons retailers and business operators must be able to buy packaging and packaging materials, including imports, with confidence. But due to weaknesses in procedures for testing non-EU imports and scaremongering in the press and media, with Bisphenol A being one of a string of examples, “There is no confidence in what is coming in,” said Richard Inns, director of packaging consultancy, PEC Partnership.
Food contact packaging legislation
Based on his team’s study of food contact packaging legislation in 68 different countries, Inns concludes that Codex Alimentarius “has failed to develop an international structure for packaging.”
“Canadian efforts are not working,” he said.Speaking at the BPF headquarters in London, Inns expanded on the causes and consequences of what he calls a regulation ‘mess.’ “There are 10 systems of packaging regulation globally, with many national variations. Risk of non-compliant packaging being used arises when external regulation seems to match EU requirements but does not. There are already wide discrepancies between the way EU states interpret packaging regulations and a growing trend for EU countries to impose their own regulations that may be more rigorous than others.”
Multiple Codes of Practice exist in Europe for specific industry sectors, but the contents are “unlikely to be known to the non-expert,” Inns said. Packaging food contact legislation is complex and difficult for small and medium sized companies (SMEs) to follow and “the supplier has to help a customer through the maze.”
Poor control over potentially non-compliant imports makes the situation worse, said Inns. The governmental UK Food Standards Agency set up a dedicated unit in 2014 to tackle crime in the food industry. The Foodservice Packaging Association (FPA) in UK is lobbying for packaging safety to be part of the Food Crime Unit (FCU) remit, “to provide a greater threat to those who might be tempted to import packaging that doesn’t meet legal requirements.”
Lorenzo Angelucci, managing director at Seda UK, a supplier of paperboard and plastics-based containers and cartons and flexibles said, “In the last six years we have seen a progressive and significant expansion of non-European food packaging business volume in Europe, in the UK in particular.” He added that products are coming mainly from the Far East and the US, which are lower grade and generally cheaper.
Seda Group is working with European and UK packaging industry bodies to raise awareness of health and safety risks in having non-aligned rules of compliance. “China has more or less a similar legislation infrastructure to Europe,” noted Angelucci, “but for four main requirements – Heavy Metals, Migration Test, Optical Brightness and Positive List. The test application refers to the ‘food contact layer only.” This could potentially exclude the printed side of carton-based packaging products where a large part of the contamination risk can occur.”
Seda wants a “fundamental difference in what is classed as food approved in the UK and EU, versus non-EU countries” to be considered by the authorities as a potential risk in terms of food contact. The suggestion is for a statistical percentage of non-EU imported packaging to be sent for lab analysis to help ensure compliance with UK legislation, managed at border control stage or with systematic market surveillance. However, procedures for testing must be ruled by sound science because, in the words of Angelucci, “Market surveillance can be dangerous for a company if analysis is incorrectly done.”