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DRAFT German Mineral Oil Ordinance

DRAFT German Mineral Oil Ordinance. Summary Sector reactions. Jan Cardon Advisor ECMA. Draft Mineral Oil Ordinance Germany Summary based on FFI circular letter 22/05. First draft : 5 May 2011 Second draft : 16 May 2013 No measure on MOSH included.

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DRAFT German Mineral Oil Ordinance

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  1. DRAFT German Mineral Oil Ordinance Summary Sector reactions Jan Cardon Advisor ECMA

  2. Draft Mineral Oil Ordinance Germany Summary based on FFI circular letter 22/05. • First draft : 5 May 2011 Second draft : 16 May 2013 • No measure on MOSH included. Analytical difficulty to split between MOSH (Mineral Oil Saturated Hydrocarbons) and POSH (Polyolefin Oligomeric Saturated Hydrocarbons) from plastics. • The second draft of the Ordinance covers only MOAH (Mineral Oil Aromatic Hydrocarbons) with chain lengths ranging from C10 to C25. No detailed definition of MOAH given. 2 BPIF Cartons 18 June 2013 - Jan Cardon ECMA

  3. According to the EFSA opinion (June 2012) certain substances in this fraction may be mutagenic and carcinogenic. • When mineral oils are migrating from paper and board packaging there is an indicative 80/20 split between MOSH and MOAH. By regulating MOAH the measure restricts indirectly also the MOSH migration. • MOAH substances should not migrate from packaging made of recycled fibres to the food. Virgin fibre packaging is excluded. 3 BPIF Cartons 18 June 2013 - Jan Cardon ECMA

  4. No limit included. In the first draft, migration limits of 0,6 and 0,15 mg into 1 kg of food were mentioned for MOSH and MOAH. Unclear where this is leading. Discussion on analytical methods and the subjective interpretation ongoing. • The text mentions how “with the currently available technology” in most cases a barrier (separate bag or barrier layer on the board) is required, in order to avoid the MOAH migration. • Transport packaging Corrugated boxes need to be labelled. “The user of the packaging needs to make sure, MOAH (C10 - C25) is not migrating into the food.” This labelling is mandatory unless a barrier is present or a risk assessment demonstrates migration is excluded. 4 BPIF Cartons 18 June 2013 - Jan Cardon ECMA

  5. Application : 2 years after publication. • Status : Draft 2 Industry federations invited to comment until the 25 June. Risk the chain length range will be broadened to C10-C35. Above C25 MOAH is only migrating in case of a wetting contact. 5 BPIF Cartons 18 June 2013 - Jan Cardon ECMA

  6. Sector reaction (ECMA/CEPI/CITPA) Sector has been seriously managing MO issue since 09/2010. (LM inks, risk assessments) 24 September 2010 www.ecma.org Public Affairs Product Safety Position note ECMA recommendation on the use of low migration inks for food packaging 6 BPIF Cartons 18 June 2013 - Jan Cardon ECMA

  7. Further responsible step forward : elimination of those MOAH substances indentified as carcinogenic in the EFSA scientific opinion (3-5 ring MOAH ...) from the entire paper and board supply chain. • Availability analytical methods ? • Many not harmful substances in • MOAH fraction. BfR Seminar 22-23 September 2011 K. Grob 7 BPIF Cartons 18 June 2013 - Jan Cardon ECMA

  8. Final objective is public health : all sources should be taken in account. (advent calendar outcome ...) INFORMATION STATEMENT ON MIGRATION ISSUE GERMANY 30 November 2012. … Concerning the information published by “Stiftung Warentest” ECMA points out that there are clear indications (also mentioned in the test article) that not only the packaging could be hold responsible as possible source of contamination. http://www.ecma.org/templates/mercury.asp?page_id=2088 8 BPIF Cartons 18 June 2013 - Jan Cardon ECMA

  9. 26 11 2012 9 BPIF Cartons 18 June 2013 - Jan Cardon ECMA

  10. Harmonised EU approach required. 10 BPIF Cartons 18 June 2013 - Jan Cardon ECMA

  11. (p. 5-6) France & Belgium BPA … EFSA should be mandated by the Member States. 11 BPIF Cartons 18 June 2013 - Jan Cardon ECMA

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