Recent risk assessments performed by the German Federal Institute of Risk Assessment (BfR) and European Food Safety Authority (EFSA) reconfirm specific migration issues and use of questionable additives in the food contact bamboo and melamine products.
Scrutiny made in the EU on food contact products.
Scrutiny has been made by the EU institutions that have shown that in recent years an increasing number of food contact materials and articles are placed on the market that is manufactured from plastic and to which bamboo and/or other ‘natural’ substances are added. A popular example is kitchenware or tableware, such as reusable plates, bowls and coffee beakers. These materials and articles are often similar in appearance and function to melamine tableware or kitchenware as they typically also consist of melamine plastic as the main structural component but also contain ground bamboo (‘bamboo-melamine’) or other similar constituents such as corn, as an additive, often functioning as a filler. Other examples include, but are not restricted to, bamboo fibers that are added to a polymer resin binder to form a composite product. The number of these bamboo-melamine food contact materials and articles placed on the market are sold on the premise of being sustainable, recyclable and natural. They are labelled and marketed as ‘biodegradable’, ‘eco-friendly’, ‘organic’ or ‘natural’ or even in some cases ‘100% bamboo’, which does not reflect the true nature of the product. In many cases their trade name and description are used in support of that marketing approach and they are not readily identified as consisting of plastic.
High values of specific migration substances
The study indicates that, from a food safety perspective, these items are not necessarily suitable for use as reusable food contact products as melamine and formaldehyde were found to migrate from these materials into food at high temperatures. In addition to BfR’s own studies, these findings were also revealed by other German federal state market surveillance agencies. In many cases, higher quantities of formaldehyde and melamine were released from bambooware than from ‘conventional’ melamine resin items. On average, the specific migration values were found to be up to 30% higher for formaldehyde and 100% higher for melamine.
Compliance verification is obligatory.
Manufacturers or importers of bamboo-melamine food contact materials and articles may not consider these materials as being plastic materials and articles by mistake or by lack of knowledge over the applicable legislation. Consequently, no verification of compliance with Regulation (EU) No 10/2011 is undertaken. This may lead to the placing on the market of materials and articles from which substances, such as melamine or formaldehyde contained in the plastic, migrate in quantities above the SMLs.
It is important to remember, that if a melamine resin is used in plastic, Regulation (EU) No 284/2011 applies for those materials and articles that fall within the scope of this Regulation.