If you package your product yourself, you must use packaging that’s suitable for food use. For consumer packaging materials that comes in contact with food (e.g. cans, jars) that come into contact with food specific health control provisions apply. Food contact materials must be manufactured so that they do not transfer their constituents to food in quantities that could endanger human health, change the composition of the food in an unacceptable way or deteriorate the taste and odour of foodstuffs.
Suitable packaging is marked ‘for food contact’ or has a symbol on it that looks like a wine glass and a fork.
Food contact materials such made from for example (recycled) plastic and ceramic must be manufactured so that they do not transfer constituents to food in quantities that could endanger human health, change the composition of the food in an unacceptable way or deteriorate the taste and odour of foodstuffs. Common restricted substances are vinyl chloride monomer N- nitrosamines, N-nitrosatable BADGE, NOGE, BFDGE and heavy metals. You must have written evidence that you’ve kept to this specific rules.
This is known as a ‘declaration of compliance’ and you can get it from your packaging supplier.
You also have to get one if you buy food that’s already packaged for sale in any of those materials.
Note that there is also specific legislation on packaging and liability that apply to all goods marketed in the EU.
Requirements specific to the manufacturing and composition of packaging
• Packaging shall be so manufactured that the packaging volume and weight be limited to the minimum adequate amount to maintain the necessary level of safety, hygiene and acceptance for the packed product and for the consumer.
• Packaging shall be designed, produced and commercialized in such a way as to permit its reuse or recovery, including recycling, and to minimize its impact on the environment when packaging waste or residues from packaging waste management operations are disposed of.
• Packaging shall be so manufactured that the presence of noxious and other hazardous substances and materials as constituents of the packaging material or of any of the packaging components is minimized with regard to their presence in emissions, ash or leachate when packaging or residues from management operations or packaging waste are incinerated or landfilled.
Requirements Specific to the Reusable Nature of Packaging
The following requirements shall be simultaneously satisfied:
• The physical properties and characteristics of the packaging shall enable a number of trips or rotations in normally predictable conditions of use,
• Possibility of processing the used packaging in order to meet health and safety requirements for the workforce,
• Fulfil the requirements specific to recoverable packaging when the packaging is no longer reused and thus becomes waste.
Requirements Specific to the Recoverable Nature of Packaging
Packaging recoverable in the form of material recycling
• Packaging shall be manufactured in such a way as to enable the recycling of a certain percentage by weight of the materials used into the manufacture of marketable products, in conformity with current EU Standards. The establishment of this percentage may vary, depending on the type of material of which the packaging is composed.
Packaging recoverable in the form of energy recovery
• Packaging waste processed for the purpose of energy recovery shall have a minimum inferior calorific value to allow optimization of energy recovery.
Packaging recoverable in the form of composting
• Packaging waste processed for the purpose of composting shall be of such a biodegradable nature that it should not hinder the separate collection and the composting process or activity into which it is introduced.
• Biodegradable packaging waste shall be of such a nature that it is capable of undergoing physical, chemical, thermal or biological decomposition such that most of the finished compost ultimately decomposes into carbon dioxide, biomass and water.
• When providing pre-packed products, good professional packaging is a must. Therefore work closely together with your EU buyers to make sure it complies with their needs.
• The EU legislation on food contact materials is quite extensive and it is not easy to prove to your EU importer that your product complies with all requirements. Therefore, EU importers of food products will require documentation on toxicology and risk assessment of chemical migration from food contact materials and/or declarations of compliance.
• An interesting substance to be aware of is Bisphenol A (BPA). BPA is known for its use in plastic bottles, but is also sometimes used in inner coatings of jar lids. At the moment the use of BPA is still allowed, but there have been several discussion recently and some buyers may require you to not use it.
• Check further details and guides on how to package your product in Europe at the European Organisation for Packaging and the Environment
• For a complete and updated list of requirements, consult the EU Export Helpdesk where you can select your specific product code under chapter 07, 08 and 20.