For a healthy food chain

ClientEarth's contribution to the European Commission's evaluation of food contact materials (FCM) rules highlights critical gaps in public health protection. The organization argues that the current lack of EU-wide harmonisation for 13 of the 17 listed FCM categories allows for inconsistent safety standards and a 'race to the bottom' due to the principle of mutual recognition. Furthermore, ClientEarth criticizes the current risk assessment model based on 'migration' limits, which allows hazardous chemicals like CMRs and EDCs to be used if exposure is deemed acceptable. They propose a 'cut-off' criterion—similar to that used in pesticides regulation—to completely prohibit these substances in FCM to better protect human health and incentivize safer innovation.

• The EU's FCM legal framework suffers from a lack of harmonisation, as only four of the seventeen FCM categories listed in Annex I are regulated at the EU level, leaving thirteen materials to the discretion of individual Member States.
• The principle of mutual recognition allows products produced under lax safety standards in one Member State to be sold in others with stricter rules, potentially creating a 'race to the bottom' regarding public health.
• Regulatory fragmentation is evident in paper and board FCM, where only nine Member States specifically regulate chemical content; of 147 substances common to two or more states, 74 have no convergence on restrictions.
• The current FCM safety approach relies on 'migration' limits, which assesses how much exposure to a dangerous chemical is acceptable rather than preventing the use of hazardous substances entirely.
• ClientEarth advocates for a 'cut-off' criterion for CMRs, noting that such a principle already exists for plant protection products (pesticides), where approval is generally impossible if a chemical is identified as a CMR.
• Endocrine disruptors (EDCs) are inadequately regulated in FCM because current risk assessments do not specifically reference endocrine disruption or criteria to identify EDCs, and five 'official' EDCs (including BPA and DEHP) are currently authorised in plastic FCM.

APA

ClientEarth (2019). For a healthy food chain. https://www.clientearth.org/media/byunkzib/for-a-healthy-food-chain-clientearth-contribution-to-the-fcm-evaluation-ce-en.pdf

Chicago

ClientEarth. For a healthy food chain. 2019. https://www.clientearth.org/media/byunkzib/for-a-healthy-food-chain-clientearth-contribution-to-the-fcm-evaluation-ce-en.pdf.

Wikipedia

{{cite press release |author=ClientEarth |title=For a healthy food chain |date=May 2019 |url=https://www.clientearth.org/media/byunkzib/for-a-healthy-food-chain-clientearth-contribution-to-the-fcm-evaluation-ce-en.pdf |access-date=23 October 2026 |via=Climate Insights Directory}}

BibTeX

@misc{clientearth2019healthy, author = {{ClientEarth}}, title = {{For a healthy food chain}}, publisher = {ClientEarth}, year = {2019}, month = may, url = {https://www.clientearth.org/media/byunkzib/for-a-healthy-food-chain-clientearth-contribution-to-the-fcm-evaluation-ce-en.pdf}, urldate = {2026-10-23}, note = {Indexed by Climate Insights Directory} }