food vacuum sealed

Packaging and food contact materials

Consultancy Services

J.S. HAMILTON POLAND IS:

  • a leading laboratory in testing of packaging for food, cosmetics and pharmaceuticals in Central & Eastern Europe,
  • an independent research center offering knowledge and experience as well as a wide range of analytical methods,
  • a reliable Partner of Food, Packaging, Plastics Processing and Paper Industry,
  • expert team ensuring impartial assessment of the Quality, Compliance and Safety of Products.

We support our Partners’ business growth and development, confirm their credibility, responsibility & innovation.

J.S. Hamilton Poland Sp. z o.o. is a laboratory that comprehensively combines consultancy services with comprehensive analytical research. Our experts team ensures an independent assessment of the quality of products.  The central laboratory in Gdynia and a network of specialized local laboratories have been offering a wide range of accredited physic-chemical, microbiological and sensory analyzes since 1949.

J.S Hamilton’s experts advise the appropriate and optimized configuration of testing plan in order to ensure compliance with the relevant national and European safety regulations, as well as with specific requirements of  clients, organizations, Brand Owners and retailers.

We offer the following consultancy services:

  • documents review and verification,
  • set-up of optimized testing plans for compliance assessment,
  • compliance assessment based on EU 10/2011, Swiss Ordinance, BfR Recommendations and relevant, Industry Guidance (EuPIA, CEPI, FCA, FEICA, JRC, EFSA, EDQM)
  • toxicological risk assessment – e.g., by TTC-concept method,
  • drafts of DoC (Declaration of Compliance) for final FCMs,
  • trainings.

Food comes into contact with many materials and articles during production, processing, storage, preparation and serving, before its eventual consumption. Such materials and articles are called Food Contact Materials (FCMs). Food contact materials are either intended to be brought into contact with food, are already in contact with food, or can reasonably be brought into contact with food or transfer their constituents to the food under normal or foreseeable use. This includes direct or indirect contact.

Food contact materials (FCMs) are widely used in everyday life in the form of food packaging, dishes and utensils, tableware, food containers, etc. When put into contact with food, the different materials may behave differently and transfer their components to the food. If transferred in large quantities, many chemicals might endanger human health, or change the food itself. Therefore, food contact materials are subject to legally binding rules at EU level, currently laid down in Regulation (EC)1935/2004, which aims at ensuring FCM safety but also the effective functioning of the internal market in FCMs raw materials and final products. The purpose of this framework legislation for FCMs is to ensure the effective functioning of the internal market for materials and articles intended to come into contact with food and secure a high level of protection of human health, as well as the interests of consumers.

(EC)1935/2004 provides general requirements that all FCMs must be manufactured in accordance with good manufacturing practice (GMP) so that they are safe and do not change the properties of food in unacceptable ways. As the general requirements for all FCMs set out under Article 3 are linked to the general obligations on GMP, separate rules on GMP are laid down in Commission Regulation (EC)2023/2006. It also specifies other rules, including those on labelling and on compliance documentation and traceability, and lays down the risk assessment process involving EFSA as part of the authorization process for substances.

 

The following are examples of key legislation currently binding in Europe:

EU FCMs requirements overview
 

General Regulations on FCM

Regulation EC 1935/2004 (on materials and articles intended to come into contact with food)
Regulation EC 2023/2006 (on Good Manufacturing Practices)
 

Specific Materials

Ceramics Directive 84/500/EEC
Epoxy Resins Regulation (EC) 1895/2005
Regenerated Cellulose Film Directive 2007/42/EC
Recycled Plastics Materials Regulation (EC) 282/2008
Active and Intelligent Packaging Regulation (EC) 450/2009
Plastics Regulation (EU) 10/2011
 

Specific Regulations

Regulation (EU) 321/2011 (restricting the use of bisphenol A in polycarbonate infant feeding bottles)
Regulation (EU) 284/2011 (import procedures for polyamide and melamine plastic kitchenware from China and Hong Kong)
Regulation (EC) 1895/2005 (restricting the use of certain epoxy resins)
Directive 93/11/EEC (regulating the release of N-nitrosamines and N-nitrosatable substances from rubber teats and soothers)

 

The declaration of compliance (DoC) is a document that contains basic information about FCMs as required by applicable laws. The DoC should contain information about the following:

  • who manufactured or imported the materials or articles or the raw materials intended for their manufacture,
  • what they are,
  • date of the declaration,
  • confirmation that the materials or articles meet relevant requirements laid down in Regulation (EC) No 1935/2004 on materials and articles intended to come into contact with food and in any specific measures,
  • information about the compliance of substances used that are subject to any restrictions and/or specifications that will allow the downstream businesses ensure compliance with those restrictions,
  • information about the compliance of substances subject to a restriction in food, about the level of their specific migration and, where appropriate, purity criteria to enable the user of these materials or articles to comply with the law,
  • specifications on the use of the material or article, such as:
  • type or types of food it is intended to be put in contact with,
  • time and temperature of treatment and storage in contact with the food,
  • ratio of food-contact surface area to volume used to establish the compliance of the material or article,
  • confirmation that the material or article complies with any rules on functional barriers when one is incorporated into the material or article.

 

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The administrator of personal data is J.S. Hamilton Poland Sp. z o.o. with headquarters in Gdynia, ul. Chwaszczyńska 180, 81-571 Gdynia. We have appointed a Data Protection Officer who can be contacted by letter or by e-mail: iodo@jsh.com.pl