Food Contact Rubbers 2: Products, Migration and Regulation, Volume 16, Number 2, 2006

Chapter 3: Regulations Covering the Use of Rubber as a Food Contact Material

3.1 European Union Legislation

At the moment there is no specific EU legislation for rubber food contact materials or articles (other than nitrosamines in babies dummies (211)). Thus all such materials or articles need to comply with the general Framework Directive 89/109/EEC (29, 32, 158) so that in normal use they will not transfer their constituents to food in quantities that could endanger health or cause unacceptable changes in the composition of food or deterioration in its organoleptic properties (i.e., taste, texture, aroma, or appearance).

3.2 Council of Europe (CoE) Resolution on Rubber Products

The CoE (an international organisation, separate from the European Union) has a committee of Experts on Materials and Articles Coming into Contact with Food, that meets under the auspices of the Partial Agreement in the Social and Public Health Field. Once adopted, the resolutions and supporting documents drawn up by these bodies are not legally binding, but members of the Partial Agreement, such as the UK, are expected to take note of them.

The CoE Rubber Resolution on food contact elastomers (APRes 2004) was adopted in 2004. This document has an inventory list of additives within it and a small section that deals with breakdown products nitrosamines and amines. The inventory list is described as Technical document No 1 List of substances to be used in the manufacture of rubber products intended to come into contact with foodstuffs. An FSA project (Contract number A03038 see Section 4.5.3) was commissioned to study the breakdown...