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Expert Interview: In-house Food Contact Law Competence!

You can’t just wrap anything around food or beverage products to package them! The Food Contact Law regulates food contact materials. These are materials that are intended to be in contact with food. These can be things that are quite obvious like a glass, a can for soft drinks, but also machinery in a food factory or a coffee machine. As food contact materials can be constructed from a variety of materials like plastics, rubber, paper, coatings, metal etc. In many cases a combination is used; for example a carton box for juices can include (from the inside to the outside): plastic layer, aluminum, paper, printing and top coating.

Knowing exactly which materials can come in contact with food or beverages is key to our success as the fourth largest flexible packaging producer in the world. This is why we have built up extensive expert knowledge in-house to best serve our customers and also support other colleagues within the Group. We spoke to Dr. Beate Ganster-Ipp from Group Coordination Regulatory Affairs at Constantia Flexibles, who has been working in this field for 9 years.


Constantia Flexibles: Tell us about the department and your work, please!

Beate Ganster-Ipp: From an organizational point of view, the Group Coordination Regulatory Affairs is a part of Research & Development CC Aluminum and Foil Laminates. Some of our main tasks are setting harmonized requirements and procedures for Safety & Compliance and of course the monitoring of regulatory developments. We also support our colleagues from Sales for example with our expert knowledge – when it comes to topics like food contact laws and regulations, migration and compliance testing as well as risk assessment.

Across the Group we are supported  by Regulatory Affairs Managers located at each of our production sites worldwide. They are in charge of the evaluation and update of food contact compliance status of raw materials, they issue Declarations of Compliance (DoC) and answer customer questions related to Safety and Compliance.

Constantia Flexibles: What is the benefit for the customer?

Our Food Contact Law competence enables us to follow up on current regulatory developments and to pro-actively develop products according to the latest Food Contact Regulations. We actively engage in work groups of the Supply Chain with the clear goal of participating in the shaping of new laws as far as that is possible. We also have Group-wide standards regarding compliance work – according to which all our sites are therefore internally audited.


Our extensive knowledge regarding migration analysis and the result evaluation for example when dealing with migration analysis is definitely a key competence when discussing with customers, institutes, or authorities. This competence is further strengthened by the capability to perform migration analysis in house with state-of-the-art equipment at the R&D facility CC Aluminum and Foil Laminates at our Constantia Teich site in Austria.

Constantia Flexibles: Food Contact Laws are especially relevant when it comes to supplying the perfect packaging to the customers from the food and beverage industries. How is this handled?

First of all, it is essential for us to be involved from the beginning of the customer-supplier relationship. The Food Safety Laws almost always are a part of the contract, this needs to be professionally handled from the start!

You see, we have about 196 countries in the world and approximately 50 percent have their own specific food contact law. This law is generally only available in the national language and only a very low percentage of used raw materials are known to have “global” compliance…you can imagine that this poses quite a challenge that requires expert knowledge – which we provide in-house as far as we can and also work with external partners in special cases.

Bottomline is, though that one basic requirement of Food Contact Legislation is more or the less the same globally – it states that substances from food contact materials shall not be transferred to food in quantities which could endanger human health. This is where we come into the picture again with our state-of-the-art migration and compliance testing!

Constantia Flexibles: Can you tell us about some of the hot topics regarding Food Safety at the moment?

Sure, one big topic is the European Legislation on Printed Food Contact Materials (FCMs). There has been no specific measure yet on EU-level, the German Draft legislation on printing inks has been put on-hold. So far, the Swiss Ordinance on printing inks is the only legislation in Europe, with detailed requirements but the European Commission intends to publish a harmonized legislation for printed FCMs by mid-2018.

Another important topic are Mineral Oil Hydrocarbons.. You probably read something about this during the Christmas time when it was a big topic for consumers and producers. Basically recycled paper and board is the main contributor among food packaging materials for Mineral Oil Saturated Hydrocarbons (MOSH) and Mineral Oil Aromatic Hydrocarbons (MOAH),  A German Draft Ordinance on Mineral Oils set  out limits for MOSH and MOAH for recycled paper & board and for the migration into food and many food producers and retailers apply those draft limits for all food packaging materials…

Constantia Flexibles: Thank you very much for the insights!