The Federal Department of Home Affairs of Switzerland has approved to amend the Regulation on food contact materials (SR 817.023.21), effective 1 December 2019.

Transitional provisions

• a) Plastic food contact materials not complying with the derogation from the specific migration requirements (Point 2a) may be imported, manufactured, labelled or marketed until 31 May 2020.
• b) Food contact articles or materials not complying with the other amendments may be imported, manufactured or labelled until 30 November 2020, and marketed until stock exhaustion.

Key amendments

1. Authorized substances as food contact materials

• Regarding the authorized substances for manufacturing printing ink, food contact plastic and silicone, besides the substances listed in respective annexes, salts of aluminium, ammonium, barium, iron, potassium, calcium, cobalt, copper, lithium, magnesium, manganese, sodium and zinc of authorized acids, phenols or alcohols are also allowed.

2. Plastic materials

• a) Regarding the specific migration requirements for plastic food contact materials, a derogation on substances which are also authorized as food flavourings shall be added.
• b) In the declaration of conformity for plastic materials, the highest ratio food contact surface area to volume ratio for which compliance has been verified (or equivalent information) shall be declared.
• c) Annex 4 on the test methods of compliance with the migration limit values shall be revised.

3. Glass, enamel and similar materials

• Food contact glass, enamel and similar materials shall no longer need the declaration of conformity.

4. Recycled paper and cardboard

• a) Recycled paper and cardboard can only be used if they are produced from production waste of unprinted fresh fibres that meet the applicable requirements.
• b) As always, they shall not have substances migrated to food in quantities that are harmful to human health or causing unacceptable change in composition or organoleptic properties of the food. Also, Good Manufacturing Practices shall be observed.

5. Paraffin and wax

• Paraffin and wax which are used to manufacture the immediate food packaging shall meet the requirements of Swiss Pharmacopoeia (Pharmacopoea Helvetica). The European Pharmacopoeia (Pharmacopoea Europaea) shall no longer be applicable.

6. Varnishes and coatings

• a) A new section for varnishes and coatings (Articles 40a and 40b) shall be added to the regulation. “Varnishes and coatings” means finished material made of organic material, in which the organic material is applied as a film to a substrate in order to create a non-self-supporting protective layer or to give the substrate certain technical properties.
• b) Varnishes and coatings shall comply with the specific requirements stated in Annex 13, and test according to Annex 4.
• c) Varnished or coated articles shall be accompanied by a written declaration containing information specified in Annex 14 at all stages of marketing except the retail stage. The responsible person shall be able to provide supporting documents upon request within 10 days.

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