Global Food Contact Materials Regulations - Module 9, FCM regulations in the EAEU

This module will look at food contact materials (FCMs) regulation applicable in the EAEU, which are the Russian Federation, Belarus, Kazakhstan, Kyrgyzstan and Armenia (in part, previously known as Customs Union, CU). After defining what is meant by FCMs, the module will examine the key regulatory requirements in these markets.

Topics of discussion will include:

• Technical Regulation (TR) of the Customs Union (CU) on FCMs, TR CU 005/2011, following the unified agreements among the EAEU member states “on safety of packaging”, including appendices 1-5
• Details on product-specific requirements and testing methods on different types of FCM and food contact articles
• Steps to attestation of conformity with the TR of the CU (EurAsian conformity = EAC conformity mark), covered only by the ‘EAC declaration’, while the ‘EAC certification’ is not applicable to packaging (closures)
• Draft amendments to TR CU 005/2011 developed to clarify individual requirements of the TR based on the results of the practice of its application – notification G/TBT/N/RUS/112 dated 12 April 2021

What to expect from the course: 

• Current regulations concerning FCMs in the EAEU
• FCM substances already placed on positive lists associated with existing FCM regulations
• Restrictions applicable to certain key-listed FCMs with respect to their specific migration limits (SMLs)
• How to carry out a worst case calculation (WCC) where experimental or theoretical (modelling) migration data is missing
• Which migration testing conditions are to be applied, with case studies 
• Analytical challenges during identification of non-intentionally added substances (Nias) that migrate into food under intended conditions of use
• Key steps to take when considering the risk assessment of FCMs migrating into food
• Steps and data requirements needed to demonstrate FCM compliance in the EAEU on obtaining the compulsory ‘EAC declaration’, and the importance of position in the supply chain

Ioan Paraschiv, PhD

Group Leader, Global Food & Food Contact Materials (FFCM) Division, Knoell, Netherlands