Subject: Safety of food contact materials: 20 years of inaction on EU’s basic rules

Dear President von der Leyen,

We, the undersigned, are deeply concerned about the current state of the EU Food Contact Materials Regulation revision (EC 1935/2004) due to its significant delay. The European Commission committed to updating these 20 year-old rules to better regulate harmful chemicals in food contact materials (FCMs) as part of the 2020 EU ‘Farm to Fork’ and ‘Chemicals Strategy for Sustainability’ initiatives. While new rules on recycled plastic in FCMs were introduced in 2022, the overall revision of the law is still pending.

FCMs, including food packaging, make up a large segment of consumer goods. Undeniable evidence shows that hundreds of chemicals possessing well-known hazardous properties are intentionally used in these products, made from both plastic and non-plastic materials. For example, more than 70 carcinogens were found in FCMs purchased from markets including the European Union. Thousands of FCM chemicals continue to be detected in human samples, such as urine, blood, and breast milk, with links to serious health effects, particularly for vulnerable populations like children and pregnant women. Many chemicals remain insufficiently tested, and current EU risk assessments do not address their cumulative toxicity.

This regulatory failure is contributing to rising health concerns. The EU is seeing an increase in cancer rates, infertility, and metabolic diseases like Type 2 diabetes. The estimated cost of exposure to endocrine disrupting chemicals, including phthalates and bisphenols found in food packaging, is €157 billion annually.

There is also growing evidence of health risks associated with some alternative materials introduced after the Single Use Plastic Directive. Studies from the Netherlands and Belgium highlight the potential dangers of these materials, making it crucial to harmonise and strengthen EU regulations on all FCMs to ensure consumer safety.

Therefore, along with political demand for long term competitiveness, sustainable circular economy solutions and creation of a strong secondary materials market in the EU, the critical aspect of safety of all food contact materials, both conventional and alternative, virgin and recycled, cannot be left behind any longer.

We thank you for your consideration of this important matter and remain at your disposal for any questions you may have.