EU Legislation on Food Contact Materials: More Safety, More Quality

The provisions, which concern all materials and articles intended to come into contact with food, are now applied in every EU member state.

The primary goals of the EU provisions are:

• To regulate the traceability of manufactured materials, reducing product recall times in case of alerts.

• To establish, promote and maintain an effective quality management system across the whole supply chain, from production to processing, distribution and importing.

In addition, the recent tightening of sanctions in case of non-compliance further testifies to the European Union's commitment to food safety.

---

The EU legislative framework on FCMs is based mainly on the two following regulations:

REGULATION (EC) NO 1935/2004
It sets out the general principles of safety and inertness for all FCMs.
Every company in the supply chain must register at the local health authority and declare that the manufactured materials, when in contact with food:

• Are not harmful to humans
• Do not change the composition of food products
• Do not alter their organoleptic properties

Any item, material or component shall be labelled or marked with the FCMs symbol and carry adequate identification to ensure traceability.

REGULATION (EC) NO 2023/2006
It sets out good manufacturing practices (GMP) to ensure the conformity of food contact materials.

The regulation establishes a series of requirements affecting the whole supply chain, which cover:

• The hygiene practices for plants
• The quality control system
• The training of staff

Meeting the requirements is quite straightforward for companies that already adhere to quality management systems, such as ISO 9001. Indeed, certain practices such as the traceability of documents are already part of the system and can easily be adjusted.

In line with the goals set by the EU, good manufacturing practices contribute to the creation of a virtuous circle, where every company in the supply chain is encouraged to maintain excellent hygienic standards through the acquisition of unified and defined methods and processes.

---

At Galdi, the internal adjustment of our processes to the provisions began several years ago. All our components are now classified in compliance with EU standards.

We also require our suppliers to provide a declaration of compliance, to adhere to GMPs and to meet FCMs regulations, including carrying out migration testing with simulants suitable for all the food products confectioned by our machines: dairy products, fruit juices, liquid egg, soups, dry food and so on.

We have also offered introductory training to support our clients and we are currently drafting an audit plan to monitor their compliance with the GMPs.
We also collaborated with some suppliers in identifying alternative solutions aimed at bringing their components into line with the requirements.

Meanwhile, our engineers are increasingly working on developing simpler designs, while reducing costly components and welding, so as to improve security parameters and testability.

Furthermore, we are investing in resources that will allow us to design safer and more hygienic fillers, in view of optimizing our machines’ monitoring and hygienic performances as well as offering highly specialised advisory to our clients.

---

First, clients should periodically ask ALL their suppliers to provide a declaration of compliance to EU regulations relevant for all the manufactured food products, before starting the filling process.
It is also essential to archive all product traceability and compliance documents, which might be required by relevant authorities during checks.

Internally, we recommend our clients to provide regular training courses to employees and to verify that all hygienic and procedural requirements are satisfied.

If there is no absolute certainty that a supplier has met the EU requirements on food contact materials, the company should ask the supplier to provide laboratory tests or perform internal ones.