Need for a better safety evaluation of food contact materials produced from resins

Historically, due to the often overwhelming complexity of the substances migrating from food contact materials (FCMs) into food, the specific legislation in Europe started from the substances used to manufacture these materials and articles. There are, however, FCMs with migrates almost exclusively consisting of reaction products, such as those produced from resins used, e.g. for coatings (epoxy resins, polyesters, organosols, trimellitic acid resins). Since the reaction products do not necessarily have the same toxicological profile as the starting substances to produce the resins, the use of authorized starting substances does not rule out the migration of compounds endangering human health. The European framework Regulation 1935/2004 requires the safety of all substances migrating from FCMs into food. Resolution AP2004/1 on coatings of the Council of Europe puts the emphasis on the safety evaluation of the migrants rather than that of the substances used for manufacturing the resins and then the coatings. Nonetheless, the Code of Practice for Coatings recently issued by industry focuses on the evaluation of the starting substances to produce resins. The authors of this paper consider the present situation unsatisfactory. It is the duty of industry to respect the legal requirements and of the regulatory authorities to ensure that these requirements are met. The authors recommend setting a time limit to have this achieved.