Changes to long-standing Dutch legislation and a new Belgian Order on coatings are to pose significant challenges for food contact coatings companies. From now on, EU still does not issused harmonized requirements for food contact coatings, although there are some general requirements under (EC) No1935/2004.
Some member states, like the Netherlands, have issued national rules for food contact coatings. In the Netherlands, FCMs are regulated by the packaging and utensils Regulations, which include positive lists of substances permitted for use in their manufacture. Coatings are covered by Chapter X, appendix A. The new draft of Chapter X includes four sections, generic coatings, metallic coatings, wax coatings and high temperature coatings. Appendix A of the Dutch regulations is also being revised to include a new Chapter, the updated testing conditions were notified by the Dutch to the European Commission on 23 July. Public comment period will end on 23 October with a extendion of three months. The updated Chapter X is expected to be notified to the Commission in 2014.
Draft Belgian Order only regulates metal packaging, flexible packaging and heavy-duty coatings. The draft of Belgian Order has not yet been notified.