Adhesives and the Framework regulation
The European framework directive 89/109/EEC, replaced on 27th October 2004 by the regulation (EC) No 1935/2004 is about the general rules for materials, substrates and articles intended to come into contact with food on an European level.
The European framework directive 89/109/EEC, describes specific rules for adhesives used in food applications. In addition, according to the definition in article 1 of the framework regulation, (EC) No 1935/2004 is valid for materials, so packaging products, in the finished state.
Article 3 of the framework regulation requires that adhesives, coatings, and other materials and articles, which are coming into contact with food, shall be manufactured in a way that it does not endanger human health, do not cause an unacceptable change in the composition of the food and do not change the organoleptic characteristics of the food. It is concluded that the final product has to be assessed when it needs compliance with the respective regulation. The manufacturer of the packaging, such as a carton folding box, has to take care that no constituent transfers to food in such quantities that there is a risk for the final consumer. If only one element is tested, e.g. the adhesive, it only represents a small part of the total packaging. This wil not be the right approach to evaluate compliance with the respective food regulations, because of the wide range and diversity of packaging materials.
Due to the huge amount of different foils, inks etc. Intercol can not test the special conditions of each customer. Moreover the organoleptic characteristics to the food can only be monitored on the packaged foodstuff and therefore fall under the responsibility of our customer.
Referring to article 17 of the framework regulation (EC) No 1935/2004 Intercol offers to declare a full traceability of all raw materials and articles of our adhesives. In addition our production sites are accredited to ISO 9001 and therefor we document all our adhesive production activities providing availability.
Unfortuneately no specific measure for adhesives exists, as in article 16 of the framework regulation the use of national provisions for the assessment of food contact is allowed. The already existing regulation for plastic materials and articles intended to come into contact with foodstuffs (EU) No 10/2011, is replacing the plastic directive and its amendments on 1st May 2011.