MOCA, Materials and Objects Intended for Food Contact, a serious food safety issue. The recurrence of serious weaknesses in the European early warning system prompts the Commission to adopt a recommendation on official public controls to be carried out by member states and reported to Brussels. With the goal of focusing on prevalent contaminations and better ensuring public health.
MOCA, food safety issues
The safety concerns recorded in theRapid Alert System on Food and Feed (RASFF), in relation to MOCAs, although slightly decreasing, often qualify as ‘serious’. Thus, materials and objects intended to come into contact with food pose serious health risks to consumers, which are very serious for children and adolescents. With particular regard to products arriving from non-European countries.
The seriousness of the problem is expressed in a couple of macroscopic examples from the alert system. A set of children’s cutlery, from China, showed migration of nickel (toxic heavy metal) more than 500 times higher than the allowable limits (55.7 mg/kg, compared with a limit of 0.1). Other tableware, also coming from the PRC, exceeded the permissible thresholds by almost 2,000 times (19,500 µg/Kg, compared to a limit of 10 µg/Kg) of aromatic amines, a family of compounds, some of which are carcinogenic, others suspected of being so.
Several toxic substances have been found in the MOCAs under alert. Heavy metals, including lead, but also formaldehyde and melamine. Given the serious public health hazards associated with such contamination, the European Commission decided to adopt a coordinated control plan. With the first objective to monitor the prevalence of different hazardous substances migrating from materials and articles intended for food contact.
MOCA, the coordinated plan of controls in the EU
European Commission Recommendation (EU) 2019/794, 15.5.19, is ‘on a coordinated control plan to establish the prevalence of certain substances migrating from materials and articles intended to come into contact with food‘. In the Annex to the recommendation, the institution of indicates the minimum number of samples for analysis in each territory. Each member state is then required to implement an appropriate control plan and report its findings to Brussels. Italy ranks first in the number of recommended minimum sampling rates (100), along with Belgium, Germany, Spain, France and the United Kingdom.
The materials to be sampled and analyzed are specified , as well as the products where significant amounts of banned substances are most likely to be detected or exceed the established limits. With reminders of critical parameters to focus on as early as the second half of 2019. In particular:
– The materials to be checked more thoroughly are various. Plastics, paper and cardboard, metals. Without underestimating materials derived from natural sources where additives are used (e.g., bamboo),
– potentially critical products are reusable coffee cups, cans, thermoformed sheets, flexible packaging, pipes, closures and lids. As well as handmade materials and objects,
– the contaminants to be monitored are both those identified as emerging risks by the scientific community (e.g., bisphenol, and those reported most frequently in Rapid Alert System notifications.
Contaminants to watch out for
Bisphenol A (BPA)-an endocrine disruptor that has been the subject of recent, but mild, restrictions and is used to make plastics and coatings for milk and cans-is at the top of the list. (2) The Commission also calls for investigation of one of its main substitutes, bisphenol S (BPS). In relation to this substance-which some studies suggest may be equally dangerous-data on migration levels are not available to date.
Phthalates-or phthalate esters, a group of substances widely used as plasticizers and processing aids-must also come under special controls, against noncompliance reported in the RASFF related to their migration into food. Phthalates are endocrine disruptors, in some cases even toxic to reproduction, dangerous with prolonged or repeated exposure. Their use is therefore prohibited in toys and limited in childcare items (baby bottles, saucers and cutlery). And yet, incredibly, they are still allowed in MOCAs.
The Istituto Superiore di Sanità (ISS), through the ‘Life pursuaded‘ project, found measurable levels of phthalates in 100 percent of the 900 children monitored (and BPA in 76 percent of the subjects). The Italian research results have therefore led the European Commission to suspect that phthalates are even used in childcare articles.
Primary aromatic amines are also considered in the recommendation. The European Commission’s own Joint Research Center, in a previous survey, found it in significant concentrations in colored paper towels.
Formaldehyde and melamine have already been the subject of a special regulation after numerous nonconformities were found on kitchen utensils arriving from PRC and Hong Kong. (3) The problem remains current although declining, with 23 cases in early 2019. Formaldehyde-whose migration limit is defined as 15 mg/kg, in the EU Plastics Framework-was classified by IARC, in 2004, as a Group I compound (definite carcinogen).
Phenol-an aromatic compound derived from benzene, used to make plastics, paints and coatings of contact materials-also appears in the Commission’s recommendation. The sources of phenol exposure are in fact multiple, according toEuropean Food Safety Authority (EFSA) assessments, to a level too high for health.
Fluorinated compounds (PFAS, PFOA) -hydrophobic and lipophobic substances that are widely used, especially in oil-resistant films (e.g., in the baking paper, fast food packaging, popcorn bags, etc.) are also considered. Once again, these are endocrine disruptors, the danger of which is emerging with increasing evidence. PFOAs are classified by IARC(International Agency for Research on Cancer) in class 2b. That is, definitely carcinogenic to animals and possibly humans, pending confirmation.
Interest in these compounds has grown in recent years because of their widespread use but also because of their high persistence in the environment. Being very stable substances, fluorinated compounds-as well as microplastics-can travel long airborne distances and reach areas as far as thousands of kilometers from production facilities. With adverse and bioaccumulation effects in living things (EPA, Environmental Protection Agency, USA).
The results of the pan-European monitoring will be used to assess whether new rules are needed. Hoping, at least once in this area, (!) to ensure a high level of health protection for European consumers.
Dario Dongo and Luca Foltran
Notes
(1) Commission Rec. EU 2019/794, 15.5.19, ‘on a coordinated control plan to establish the prevalence of certain substances migrating from materials and articles intended to come into contact with food‘, at https://eur-lex.europa.eu/legal-content/IT/TXT/?qid=1558908819737&uri=CELEX:32019H0794
(2) Reg. EU 2018/213, 12.2.18, ‘on the use of Bisphenol A in paints and coatings intended to come into contact with food and amending Regulation (EU) No. 10/2011 regarding the use of this substance in plastic materials intended to come into contact with foodstuffs‘
(3) Reg. EU 284/11, 22.3.11, ‘laying down special conditions and detailed procedures for the import of polyamide and melamine plastic kitchenware originating in or consigned from the People’s Republic of China and Hong Kong Special Administrative Region, China‘
Dario Dongo, lawyer and journalist, PhD in international food law, founder of WIISE (FARE - GIFT - Food Times) and Égalité.
Expert in packaging and materials intended to come into contact with food substances and related legislative changes. He manages the information site foodcontactmaterials.info on European and extra-European regulations in the field of materials intended for contact with food.
