Table 1: Comparison of regulatory approaches under food laws to chemical migration from packaging into food Key elements Australia/NZ Canada USA EU China Who is responsible In Australia, the Responsibility lies Responsibility lies Responsibility lies with Responsibility lies with food for CMPF responsibility lies with with food retailer with packaging food retailer retailer food businesses or manufacturer businesses that sell food packaging. In New Zealand, responsibility lies with food traders. Descriptor of No requirements Trade names Chemical Names Chemical Names Chemical Names chemicals used for packaging Regulatory Safe and suitable No lists (except for Positive lists of FCMs shall be safe and Composite of both EU and Food Act provisions. resins) maintained adhesives and not change the US regulations measures/approaches in place by Health Canada. coatings, Paper and properties of food in Maximum limits for paperboard, Polymers unacceptable ways. A food contact notification acrylonitrile, tin and Pre-market and Adjuvants and must be submitted and vinyl chloride in voluntary clearance production aids. Positive lists and approved by the Ministry of standard 1.4.1 and by a letter of no specific migration limits Health. DEHP in bottled objection A pre-clearance for plastics in direct water (Standard 2.6.2 requirement that any contact with food. Positive lists of >1500 Non-Alcoholic substance that is permitted food contact Beverages and intended to become a The European Food additives (including Brewed Soft Drinks) component of food Safety Authority (EFSA) monomers), specific migration under the WHO (eg. migrates from conducts a risk limits, maximum permitted Drinking water packaging into food) assessment and quantity and other guidelines) must be: generally prescribes the way in restrictions. recognised as safe which an application for (GRAS), used in a listing in suitable Regulations apply to plastics, accordance with a regulation is to be paper, ink, coatings and sanction of approval submitted, noting the rubber. issued prior to 1958, need for a technical the subject of a dossier to comply with of the guidelines published “Threshold Regulation” to indicate what is
Table 1: Comparison of regulatory approaches under food laws to chemical migration from packaging into food Key elements Australia/NZ Canada USA EU China Who is responsible for CMPF In Australia, the responsibility lies with food businesses or businesses that sell food packaging. In New Zealand, responsibility lies with food traders. Responsibility lies with food retailer Responsibility lies with packaging manufacturer Responsibility lies with food retailer Responsibility lies with food retailer Descriptor of chemicals used for packaging No requirements Trade names Chemical Names Chemical Names Chemical Names Regulatory measures/approaches in place Safe and suitable Food Act provisions. Maximum limits for acrylonitrile, tin and vinyl chloride in standard 1.4.1 and DEHP in bottled water (Standard 2.6.2 Non-Alcoholic Beverages and Brewed Soft Drinks) under the WHO Drinking water guidelines) No lists (except for resins) maintained by Health Canada. Pre-market voluntary clearance by a letter of no objection Positive lists of adhesives and coatings, Paper and paperboard, Polymers and Adjuvants and production aids. A pre-clearance requirement that any substance that is intended to become a component of food (eg. migrates from packaging into food) must be: generally recognised as safe (GRAS), used in accordance with a sanction of approval issued prior to 1958, the subject of a “Threshold of Regulation” FCMs shall be safe and not change the properties of food in unacceptable ways. Positive lists and specific migration limits for plastics in direct contact with food. The European Food Safety Authority (EFSA) conducts a risk assessment and prescribes the way in which an application for a listing in suitable regulation is to be submitted, noting the need for a technical dossier to comply with the guidelines published to indicate what is Composite of both EU and US regulations A food contact notification must be submitted and approved by the Ministry of Health. Positive lists of >1500 permitted food contact additives (including monomers), specific migration limits, maximum permitted quantity and other restrictions. Regulations apply to plastics, paper, ink, coatings and rubber.
P1034%20Packaging%201CFS%20SD6%20Summary%20of%20international%20approaches%20to%20CMPF.docx