Repeated use food contact materials: A categorisation approach in support of risk assessment

The current migration assessment requirements regarding safety of plastic food contact materials in Europe (e.g. kitchen utensils, kitchen appliances, packaging, etc.) widely rely on migration testing. According to Annexe V of Regulation (EU) No 10/2011 migration testing requirements consider the specificities of repeated use applications only to a limited extent. Repeated use food contact materials should be tested for three consecutive times at the worst-case contact time and temperature. If diffusion controlled, the migration decreases with increasing number of repeated uses. Compared to single use applications, repeated use food contact materials typically exhibit much shorter contact times, much lower ratios of surface in contact with a given amount of food, and in some cases higher temperatures. Compared to real use, in many cases highly overestimated migration testing result are observed. Overestimation by testing at the beginning of use may be coupled with underestimation at later times. National legislation of the Netherlands on food contact materials has established a classification for repeated use rubber materials based on the R-value indicating whether migration testing is required or not. The R-value considers in more detail specificities of repeated use applications. This publication investigates to which extent it is possible to apply the approach to plastics food contact materials in Europe. It is practically impossible to perform migration tests for various materials by putting them many times in contact with food over a long period of time, typically several years, at several temperatures and areas to food amount ratios migration. Modelling has therefore been used to predict migration from various food contact materials under different repeated use scenarios. Realistic diffusion properties of materials and migrant partitioning behaviour have been assumed to minimise the risk of underestimation.