2013-01-12 16:32:29
The quality of products and services is regulated in France by the Consumer Code of 1993. According to this text, the person responsible for the first placing on the market of a product must ensure that the latter meets the rules in force (general obligation of conformity). It is therefore the supplier of raw materials who must guarantee to his customer their ability to come into contact with food by providing a written declaration of conformity, issued by an approved laboratory. At European level, a general regulations defines the characteristics of materials and objects intended to come into contact with foodstuffs.
The basis of this regulation is the principle of inertiaaccording to which the materials must not transfer constituents to foods in quantities likely to present a risk to the consumer or to modify the organoleptic characteristics or composition of the food. The inertia of materials in the regulatory sense is therefore above all a physico-chemical inertia.
Types of materials in contact with food
The general regulation distinguishes 17 types of materials that may come into contact with food: plastics (including varnishes and coatings), regenerated cellulose, elastomers and rubber, paper and cardboard, ceramics, glass, metals and alloys, wood , textile products, paraffin waxes and microcrystalline waxes, active materials and objects, glues, cork, ion exchange resins, printing inks, silicone, varnishes and coatings.
Certain types of materials are, moreover, subject to specific regulations specifying this general regulation, via specific guidelines. Thus, three types of materials are the subject of a harmonized regulations at European level, namely plastics (Regulation (EU) No. 10/2011 of January 14, 2011), ceramics (Directive 84/500 of October 15, 1984), and rubbers (Directive 93/11/EEC of March 15, 1993).
Others are subject only national regulations in the absence of harmonized European regulations : silicones (order of November 25, 1992), rubber materials (order of November 9, 1994), stainless steels (order of January 13, 1976) and aluminum (order of August 27, 1987).
The substances that make up materials also obey rules
A list of substances authorized for the manufacture of materials appears in each regulation. This list is supplemented by information on conditions and restrictions of use and purity criteria.
For substances subject to European regulations, it is the EFSA (European Food Safety Authority) which is responsible for the health evaluation of new substances intended to enter the composition of materials in contact with foodstuffs and therefore their possible inclusion in the list of authorized substances.
For materials not harmonized at European level, the assessment is carried out at national level. In France, it is ANSES which carries out this assessment.
Finally, for materials not subject to specific national or European regulations, the general regulations prevail.
Good manufacturing practice guides
In order to compensate for the absence of specific regulations and to facilitate the application of the general regulations, certain professional sectors have taken the initiative of drafting good manufacturing practice guides comply with the general European regulation. These are voluntary documents. They are evaluated by the member states to ensure that they have been developed in compliance with the regulation and that their content can be put into practice in the sector for which they are intended.
In France, they are communicated to ANSES for opinion. In the event of a positive opinion, they are presented to the CNC (National Consumer Council) for information, before publication in the Official Journal.
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