Empac food contact commission (FCC)

 

Pierre Sirbat Chairman

David Smith Secretary

Introduction
Food contact legislation, most particularly in Europe, is becoming increasingly complex as the precautionary approach to the protection of the consuming public becomes ever more prevalent. In order to ensure that Empac membership is as prepared as possible for regulatory and scientific developments, the Food Contact Commission enjoys the support of all the Empac member associations across Europe. In order to increase influence at the regulatory level, and better to prepare defensive positions in the area of food contact materials and articles, the FCC works in conjunction with other value chain European associations, from additive suppliers down to food fillers, in a light metal packaging Joint Industry Group (JIG).
The FCC is chaired by Pierre Sirbat, VP Environment and Quality for Crown Europe, with David Smith, Technical Manager of the UK MPMA, acting as secretary.
FCC meets normally three times per year and prefers to rotate the meeting venue around member association countries so that 'non-regulars' periodically get a chance to attend to gain a knowledge of the work of the FCC, and of course to contribute. 'Regular' delegates comprise representatives of at least eleven can, end or closure manufacturers, technical secretariats from some national associations and representation from tinmill product manufacturers (APEAL), end sealant manufacturers and a specialist test institute. Where appropriate, expertise from additional areas will be invited in as relevant to the issues of the day. These could relate to substrate, e.g. European Aluminium Association (EAA), or national and international consumer health authorities where specific issues need to be discussed.

Main activities

• 'Issue management' – This covers pressing 'substance' issues such as bisphenol A, melamine and migration from set-off of external print components – sometimes short-term, sometimes active over several years, and often exaggerated because of the associated media activity. Much of this work is carried out in conjunction with other parts of the value chain via a Joint Industry Group (JIG) as previously stated. Member analytical laboratories support this effort. Given that these substance issues are often global in their impact, FCC and the JIG work in close co-operation with, in particular, their North American counterparts, e.g. North American Metal Packaging Alliance (NAMPA), Can Manufacturers Institute (CMI), Society of the Plastics Industry (SPI) and American Chemistry Council (ACC).
• 'Regulatory proactiveness' – This entails being present at the stage when regulation is being drafted by the regulatory authority, primarily but not exclusively the European Commission, in order to shape the regulation before its adoption into a form which is logical and capable of being complied with, before its actual adoption. Currently ongoing examples would be the changes to the European migration test rules, the evolution of the REACH guidelines and the generation of a Good Manufacturing Practices guide to members. Again, strength is gained from operating as a JIG.
• 'Networking' – Which impacts on the previous two, and means the formation and maintenance of useful contact routes, particularly inter-industry and with relevant European and national authority bodies.

Guide to good manufacturing
Manufacturers of metal packaging and closures intended to come into contact with foodstuffs for human or animal consumption are obliged to provide fit-for-purpose products whilst ensuring proper consumer health protection. The good manufacturer disciplines required are enforced in Europe through Commission Regulation (EC) No. 2023/2006 “on good manufacturing practice for materials and articles intended to come into contact with food”. This link leads to a guideline document compiled by the Food Contact Commission of Empac to help members towards the achievement of best manufacturing and hygiene practices with a purpose to ensure full integrity of metal packaging and protection of its contents over the full shelf life.