Analysis of constraints on effective risk analysis: harmonisation in a circular economy and implications from Food Contact Material recycling

The need for a circular economy is clear, but practical and legal routes to achieve this are less self-evident. This is especially true for the food system; how to achieve a safe circular food system requires technical and regulatory knowledge that is often missing, uncertain, or proprietory. For example, the recycling of food contact materials (FCMs) results in an increased presence of non-intentionally added substances (NIAS). The monitoring of such substances remains very limited, but their presence can lead to serious health risks. The unpredictable chemical effects of the recycling of food contact materials, both direct- and indirect effect (through metabolites), poses a real challenge to risk assessments by European Food Safety Authorities. To achieve a circular and safe food system, effective risk analysis is vital. Risk analysis of this kind would ensure both a clear overview of the hazards related to circular food systems and pinpoint any regulatory obstacles to achieving such systems. This research asks How can effective risk analysis be achieved within the Europe’s Food Safety System given the shift to a circular food system? To answer this question, this project maps risk analysis networks in several different EU countries and identifies constraints in these networks that potentially prevent them from adequately responding to circular issues. It also aims to identify which emerging issues are expected when, and where within the same EU+ setting. The research is part of FoodSafety4EU, a project that aims to develop a multi-stakeholder platform for European food safety.