HIGHLIGHTS ON PIM (Plastic Implementation Measures - DRAFT Regulation susbstituting European Directive 2002/72/EC)

The year 2011 promises a year of great change for producers of packaging designed to contact food substance. Following several modifications and upgrades that included the Directive 2002/72/EC (Directive on the plastic for use in food contact substances), the Commission issued a proposed new regulation, which is currently in draft release, but make significant changes to the current legislation, both as regards materials and articles in question, both as regards the methods of tests.

The first and fundamental change is the application of this regulation, even in multi-layer materials, whether or not composed exclusively of plastic materal. While the Directive 2002/72/EC was related only to items or materials consist only of polymer (plastic cover and substrate), the current regulation also applies to those items that have a different substrate than plastic (metal, glass ...). It will therefore also interested pans lined with polymer but which obviously have a metallic substrate (eg aluminum) and other items that previously did not fall under the scope of the Directive.

Rubber and silicone instead, are excluded from the scope of the new Directive.

Another new concept introduced is the “functional barrier”, a term already widely discussed during the year between producers and experts. Behind this functional barrier polymer material can also be used unapproved substances, if it is demonstrated that there is no migration to the food (meaning as stated in Regulation 1935/2004)

Even for the producers of plastics, already affected by the old directive, there are substantial changes, both in terms of the contact conditions during testing for food (time and temperature) both in the types of simulants to be used and to which the various items must be checked.

The water is no longer included in the food simulants, replaced by 10% ethanol in aqueous solution, as at present there are no substitutes for any media of olive oil (simulant for fat-based foods). It is untroduced a particular simulant (MPPO) for verification of specific migration to cover the dry food and also the allocation of various food simulants in relation to the type of food specific change to better represent the behavior of food in contact with the finished article .

New classes of time and temperature are introduced in order to cover many conditions in which an item can be used (provided in excess of 30 days of contact for example, packs of supermarket shelf), same goes for the temperature tests, and remain the special cases for articles intended for multiple conditions in succession (sterilization and subsequent storage for example).

The evaluation of workers in the sector is positive as the number of amendments to Directive base were often confused because of the lack of clarity in the Draft while this new approval, replacing and incorporating all previous ones, seems to contain all the tools needed to verify eligibility food and is a great step forward towards the harmonization of European law.