HomePackaging and MOCAPFAS, ban in Denmark on MOCAs in paper and cardboard

PFAS, ban in Denmark on MOCAs in paper and cardboard

MOCAs remain the black box of food safety in Europe, in an abyss rather than a gap in sector legislation. To remember - once again - a group of ubiquitous toxic chemicals, the perfluorinated compounds, PFAS. That the kingdom of Denmark, in the silence of Brussels, is about to banish from paper food packaging and cardboard.

MOCA and chemical safety of food, the black box in the abyss

15 years have passed, from the affirmation in Europe of general criteria to oversee the safety of materials and objects in contact with food (MOCA or FCM, Food Contact Materials). (1) However, these criteria are still lacking in implementation on the most critical materials. It is an abyss, rather than a lacuna, in a legal system that should be based on the precautionary principle and instead tolerates absolute silence on the toxic substances contained in everyday objects, often destined to migrate into our foods.

The most common materials used to make food packaging therefore lack the rules that define which substances to admit and which to prohibit, which risk factors to consider and so on. In two words, conditions and prohibitions, based on specific risk assessments. Thus - 15 years after the global crisis linked to the contamination of infant formulas with carcinogenic ink - inks such as adhesives and adhesive materials, as well as paper-based products and numerous other materials in Europe are still devoid of ad hoc rules. . (2)

The giant in trance - also known as the European Commission - should publish by the end of 2019 an 'evaluation report' on the legislation on food contact materials and its (in) suitability to ensure the chemical safety of food. (3) Following the scheme of Later Regulationinstead of Better regulation, that we recently denounced in the case of endocrine disruptors.

The operators of the supply chain - namely i producers, importers but also users e distributors, also through ecommerce, of MOCA - cannot in any case shirk the responsibility of guaranteeing their safety. (4) And it is therefore, among other things, that the Member States most attentive to the health of their citizens have decided to adopt national legislation for its protection, without waiting for the giant in trance.

France, for example, took drastic measures on bisphenol A (endocrine disruptor, yet admitted in Europe). Germany has defined specific rules for adhesives that can be used on food packaging. But it is Denmark that has made the most significant breakthrough on a category of particularly problematic substances frequently used in FCMs, the perfluorinated compounds.

PFAS, the (poisonous) 'eternal substances'

The perfluoroalkyl organic substances (PFAS) are defined 'forever chemicals', due to their extreme resistance to degradation in the environment. (7) It is a heterogeneous group of over 4.500 man-made chemicals, formed by a chain of variable length carbon atoms, where the hydrogen atoms bonded to carbon are replaced by fluorine.

The PFAS they are widely used in materials in contact with food, first of all to treat paper and cardboard on the surface. Packaging from fast food, but also baking paper. Because of their repellence to water and fats, due precisely to the presence of numerous carbon-fluorine bonds. On closer inspection, however, paper can be made repellent to water and grease without the need for fluorine-containing substances. And it is on this aspect that the measures of the Danish government focus.

PFAS in paper and cardboard MOCAs, chemical safety, the Danish initiative

The Danish Veterinary and Food Administration - part of the Ministry of the Environment - ha 'long not recommended'' the use of PFAS in contact materials. Some operators have thus gradually phased out these substances from their products, on a voluntary basis. Following the assessments expressed by the European Food Safety Authority on 13.12.18 regarding the dangerousness of 2 PFAS, the Danish government has started working on a draft law just defined, whose entry into force is expected to July 2020. (5)

'I don't want to take the risk that harmful fluorinated substances (PFAS) migrate from packaging to our food. These substances represent such a health problem that we can no longer wait for the EU'(Mogens Jensen, Minister for Food, Agriculture and Fisheries, Kingdom of Denmark, 2.9.19. See note 6).

The use of recycled materials based on paper and cardboard will still be allowed in Denmark, after the ban, provided that they - where they contain the substances under consideration - are separated by a barrier capable of excluding migration phenomena in the food. (7)

PFAS, the risks and necessary measures in Europe and in the world

The risks associated with exposure of humans and animals to fluorinated substances - through diet, drinking water and the environment - is linked to their accumulation in the body. (8) Recent studies have shown the danger of some PFAS to health, as they are capable of negatively influencing growth, learning and behavior in infants and children. In addition to reducing fertility and interfering with the endocrine and immune systems, as well as increasing cholesterol levels.

The initiative of Denmark it is undoubtedly commendable and yet inadequate to protect public health with respect to the risks associated with exposure to perfluorinated compounds. they are used in many other applications in current use. In the production of PTFE (Teflon and similar), the coating used in many non-stick pans, for example. In addition, since the 50s, in emulsifiers and surfactants present in cleaning products, insecticides, protective coatings. They are then used in the production of waterproof clothing, products for printers, photographic films, wall surfaces, materials for microelectronics. And above all, in fire-fighting foams (used in many contexts, aircraft and motor vehicles but also oil platforms) and paints, which in fact represent one of the main causes of environmental pollution.

UNEP (United Nations Environmental Program) began negotiations with the representatives of 180 countries in May 2019. (9) With the aim of reaching an agreement on the global ban on toxic chemicals that are carcinogenic or otherwise seriously dangerous (eg. PFOA, PFAS, PFOS). However, the government delegations and the European Commission itself objected, asking for derogations for a dozen sectors. From textiles to pharmaceuticals, microelectronics, fire-fighting foams, etc. The most dignified objectives - to strengthen three treaties on dangerous substances, including the 'Stockholm Convention on Persistent Organic Pollutants'- they are so, once again, gone. And Sustainable Development Goals (SDGs) move away.

Environmental pollution from PFOA, PFAS, PFOS, meanwhile, continues in the five continents. These compounds have often been detected in concentrations, even significant ones, in environmental samples and living organisms, including humans. This is what emerges from hundreds of scientific studies and monitoring also carried out by public agencies, including the EPA (Environment Protection Agency, an understatement, in the US). The 'eternal' substances, as they were already defined by their inventors, continue to poison the planet. Italy too, as is well known, with epidemic effects in Veneto.

The high resistance of this group of substances to the processes of thermal degradation, biodegradation, hydrolysis, metabolization associated with the equally high solubility in water has prompted the Higher Institute for Environmental Protection and Research, ISPRA, to start a specific program for monitoring their presence in surface and underground water bodies. (10) From politics, ca va sans dire, no signal.

Dario Dongo and Luca Foltran


(1) See reg. CE 1935/04. The sanctions in Italy were introduced only after 13 years (!), By means of Legislative Decree 29/2017. See https://www.foodagriculturerequirements.com/archivio-notizie/moca-materiali-e-oggetti-a-contatto-con-gli-alimenti-le-sanzioni-in-italia_1

(2) Refers to the ITX case, a dangerous contaminant migrated from packaging inks into infant milk produced by Nestlé and marketed all over the world

(3) See Food contact materials, roadmap on the European Commission website

(4) For further information on the subject, please refer to our free ebook 'Food safety, mandatory rules and voluntary standards', up https://www.greatitalianfoodtrade.it/libri/sicurezza-alimentare-regole-cogenti-e-norme-volontarie-il-nuovo-libro-di-dario-dongo

(5) EFSA. Risk to human health related to the presence of per fl uorooctane sulfonic acid and per fl uorooctanoic acid in food. EFSA Journal 2018; 16 (12): 5194. doi: 10.2903 / j.efsa.2018.5194, https://www.efsa.europa.eu/en/efsajournal/pub/5194

(6) See Ministry of Food, Denmark, press release 2.9.19,

(7) NB: in Italy the use of recycled paper is allowed only in the packaging of solid dry foods (e.g. salt, sugar, rice, dry pasta)

(8) A number of studies performed on various animal species indicate the liver as the main target organ

(9) See Stephanie Nebehay. China seeks loophole as UN nears pact banning toxic chemical - activists. Reuters, 1.5.19,

(10) ISPRA (2019). Guidelines for the design of monitoring networks for perfluoroalkyl substances (PFAS) in surface and underground water bodies. ISBN: 978-88-448-0950-8, http://www.isprambiente.gov.it/it/pubblicazioni/rapporti/indirizzi-perla-progettazione-delle-reti-di-monitoraggio-delle-sostanze-perfluoroalchiliche-pfas-nei-corpi-idrici-superficiali-e-sotterranei

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.

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