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The European Union's rapid alert system for food and feed (RASFF) is a network system that connects the food and feed safety authorities of EU member states, the European Commission and the European Food Safety Authority. RASFF is not only an important part of the EU food safety regulatory system, but also an important channel for global understanding of food contact materials.
EQO summarized and analyzed the RASFF notification of food contact material (FCM) products in China in the first half of 2019 (January 1 to June 30, the same below), in order to help you understand the hot spots and changing trends of EU countries on FCM safety issues, so as to provide reference for enterprise product design and production, and enhance China's ability to respond to EU trade technical barriers.
General briefing
In the first half of 2019, the statistics of food contact material cases reported by RASFF on a monthly basis are shown in Figure 1.
Figure 1 Food contact materials reported by RASFF on a monthly basis in the first half of 2019
As can be seen from the data in the figure, in the first half of this year, the EU RASFF issued a total of 75 cases of food contact material notification, of which 62 cases were notified to China, accounting for 82.7%, and the proportion reached 100% in January. In addition, the number of cases notified to China in the first half of this year increased by 63.2% compared to the first half of 2018 (38 cases).
The specific report is analyzed as follows:
Analysis of reported products and items
Among the notified food contact materials in China, plastic products are the most, with 32 cases, accounting for 51.6% of the total number of notified food contact materials made in China, followed by bamboo products and metal products, accounting for 25.8% and 16.1% respectively (see Figure 2 for details).
Figure 2 Statistical chart of notification materials and products
Plastic products:
v In the first half of this year, 32 cases of plastic products were reported, accounting for about 50% of the total number of notifications. Among them, the plastic products with the largest number of notifications are melamine products, with 15 cases, accounting for 47% of all notified plastic products, and the high-risk substances of melamine products are formaldehyde and melamine; The second is nylon products, which are mainly primary aromatic amines with high-risk substances.
Figure 3 Risk substances for plastic products
Bamboo products: Bamboo products in the first half of this year in the notification is also frequently on the list, was notified 16 cases, accounting for 25.8% of the total number of notifications, this type of material high-risk substances are formaldehyde and melamine. Some bamboo fiber products have a high melamine migration due to the mixing of other materials in the production process.
Fig.4 Risk substances for bamboo products
Metal products: Metal products ranked third with 10 cases, accounting for about 16.1% of the total number of notifications. The main risk substances are heavy metals such as nickel, chromium, lead, manganese. Of these, two were reported to involve excessive total migration.
Fig. 5 Risks for metal products
Silicone products: 2 cases were reported in the first half of this year, and the reasons for the notification were high volatile organic compounds.
Coated products: In the first half of this year, 1 case was reported, and the reason for the notification was coating peeling and the total migration volume was too high.
Paper products: 1 case was reported in the first half of this year, and the reason for the notification was unsuitable sensory characteristics (odor).
Analysis of the reporting countries and their concerns
The statistics on the number of notifications from EU member states are shown in Figure 6. Italy, Germany and Spain are the top three countries in terms of the number of notifications, of which Italy has 12 notifications in half a year, accounting for 19.4% of the total number of notifications, followed by Germany, with 8 notifications, accounting for 12.9% of the total number of notifications. According to the collation and analysis of the RASFF notification data in the first half of the year, it can be seen that the most reported products in Italy are metal products, and among the 12 cases notified by Italy, 7 are related to metal products, accounting for 58.3%. Therefore, exporters need to pay special attention to the relevant legal system in Italy, especially the food contact material regulations related to metal materials, in order to prepare for the response.
Figure 6 Statistics on the number of notifications from EU member states in the first half of 2019
In addition, the priority substances notified by EU member states are different, and the corresponding products exported to these countries need special attention. For example, Italy's notification of nickel migration and comprehensive migration is mainly for stainless steel products; Nearly 90% of the formaldehyde migration notifications in Spain are melamine products; Primary aromatic amines in the United Kingdom are mainly targeted at nylon products; Lithuania, on the other hand, is concerned about the deterioration of sensory properties.
Figure 7 Analysis of notifications by EU member States
Suggestions for coping
In view of the characteristics of the EU RASFF notification and the collation and analysis of the notification data in the first half of 2019, the following countermeasures are put forward for the majority of exporters:
Plastic products: Combined with the analysis of China's reported cases in the first half of the year and the past two years, the attention of EU countries to plastic products is concentrated on nylon and melamine products, especially in United Kingdom and Spain. Among them, nylon products were notified because of excessive migration of primary aromatic amines, and melamine products were notified because of formaldehyde and/or melamine.
Exporters of nylon and melamine products are reminded that under Directive (EU) No 284/2011, the EU has introduced special measures for melamine and nylon plastic tableware and kitchenware produced or shipped from Chinese mainland and Hong Kong, and has strengthened entry control. The importer must provide a statement that the formaldehyde in the melamine product meets the EU limit of 15 mg/kg and that the nylon product shall not contain primary aromatic amines, and attach the corresponding test report. Imported goods will be sampled and tested at a rate of 10 per cent by the competent authorities of the Member States.
Bamboo products: In the first half of this year, 16 cases of bamboo products were notified, accounting for 25.8% of the total number of notifications, and 8 countries in the EU member states issued notifications for such products, especially products sold to Poland, with special attention to the migration of formaldehyde and melamine.
Metal products: The number of notifications of metal products ranked third in the total number of notifications in the first half of the year, with 10 cases, of which 7 cases were reported from Italy. The reason for the notification of this type of product is mainly focused on the high migration and total migration of nickel, so special attention should be paid to the limit requirements of heavy metals for stainless steel and steel products exported to Italy.
Deterioration of organoleptic properties: In the first half of this year, Lithuania reported three cases of products that led to the deterioration of the organoleptic properties of food, of which two were plastic products and one was paper products. Therefore, it is particularly important to remind that when exporting to the European Union, especially Lithuania, it is necessary to pay attention to factors such as the deterioration of sensory characteristics.
