Where it comes to consumer protection, the whole paper and board packaging sector has cooperated at national government and EU level for many years, and complies with EC regulation 1935/2004, which covers all materials which come in direct contact with food.

In addition, the European associations CEPI (Confederation of European Paper Industries) and CITPA (International Confederation of Paper and Board Converters in Europe) have now launched a voluntary Industry Guideline for the Compliance of Paper & Board Materials and Articles for Food Contact.

The aim for a paper and board industry guideline is to offer a route to compliance with EC regulation, and that it integrates with existing management systems, offers flexibility to allow for different processes and materials, facilitates straightforward auditing, is based on realistic risk assessment and above all is specifically applicable to the manufacture of paper and board food contact material.

Many of the materials which come into direct contact with food, such as cellulose film, plastics and ceramics, are subject to additional, material-specific directives or measures which apply uniformly throughout the EU. For paper, on the other hand, the picture is fragmented, with countries such as Germany, France, the Netherlands and Italy, having legislation specific to their domestic producers, while other countries simply conform with the more general, non-material specific regulation 1935/2004. The unintended impression given to buyers is that compliance for paper and board is less clear than for other materials.

So it is against this background where concern is possibly being created by omission, that a European paper packaging value chain working group has compiled the voluntary Industry Guideline for the Compliance of Paper & Board Materials and Articles for Food Contact (the Guideline).

The Guideline will refer to those aspects of quality assurance which are of most significance to the European Commission, namely to ensure that paper and board meets the quality standards appropriate to their intended use. This means they will not endanger human health by causing an unacceptable change in the food’s composition or deterioration in the food’s organoleptic properties (the way it tastes, looks, feels and smells).

Standards for consumer protection are not fixed forever, so the Guideline allows for future developments, such as biological tests developed in a joint industry/EU R&D project known as Biosafepaper. This will certainly address some concerns regarding assessment of hitherto non-authorised substances found in recycled packaging. The Guideline is a moving document, capable of being modified quickly in the light of scientific advances.

A Good Manufacturing Practice (GMP) for the industry is also being prepared. Put simply, the Guideline spells out the rules, and the GMP describes a management system for those rules to be obeyed.

The industry backs the Guideline. There have been two full internal industry consultations within the complete paper packaging chain and the Guideline was also peer reviewed by Pira International.